Gooseberry Natural Resources, LLC v. Condesa, Inc. et al

Filing 52

Joint MOTION for Extension of Time to File /Submit a Proposed Docket Control Order and Discovery Order by Gooseberry Natural Resources, LLC, Proven Ways, Inc.. (Attachments: #1 Text of Proposed Order)(Smith, Melissa)

Gooseberry Natural Resources, LLC v. Condesa, Inc. et al

Doc. 52

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

GOOSEBERRY NATURAL RESOURCES, LLC, Plaintiff, Civil Action No. 2:10-CV-210-TJW v. CONDESA, INC., MASS MEDIA DISTRIBUTION, LLC MEK ENTERPRISES d/b/a ERELEASES.COM, PROVEN WAYS, INC., PR WORLDWIDE, INC., and RV MEDIA, LLC d/b/a PR 18 NETWORK, Defendants. JURY TRIAL DEMANDED

JOINT MOTION FOR EXTENSION OF TIME TO FILE A PROPOSED DOCKET CONTROL ORDER AND DISCOVERY ORDER Plaintiff Gooseberry Natural Resources, LLC and Defendant Proven Ways, Inc. (collectively, the "Parties") file this Joint Motion for an Extension of Time to File a Proposed Docket Control Order and Discovery Order and would respectfully show the Court the following: Currently, the deadline for the Parties to submit a proposed docket control order and discovery order is March 2, 2011. See Dkt. No. 46. The Parties are diligently working on submitting a proposed docket control order and discovery order to the Court but request a short extension of time in order to finalize these proposed orders. As such, the Parties request an extension, through and including March 16, 2011, to submit a proposed docket control order and discovery order to the Court.

Dockets.Justia.com

For these reasons, the Parties respectfully request that this Court enter an Order extending the deadline to file a proposed docket control order and discovery order through and including March 16, 2011.

DATED: March 1, 2011

Respectfully submitted, /s/Melissa Richards Smith Melissa Richards Smith Texas State Bar No. 24001351 GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, Texas 75670 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEY FOR PLAINTIFF

/s/David Kent Anderson (with permission) David Kent Anderson Anderson & Cunningham PC 1001 Fannin Street, Suite 270 Houston, TX 77002-6712 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEY FOR DEFENDANT PROVEN WAYS, INC.

CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by U.S. mail or facsimile transmission, on this the 1st day of March, 2011.

/s/Melissa Richards Smith Melissa Richards Smith