Vertical Computer Systems, Inc. v. Interwoven, Inc. et al

Filing 38

Agreed MOTION for Extension of Time to File Answer by LG Electronics Inc, LG Electronics Mobilecomm USA Inc. (Attachments: # 1 Text of Proposed Order re EOT to Respond to the Complaint)(Healey, David)

Vertical Computer Systems, Inc. v. Interwoven, Inc. et al

Doc. 38

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION VERTICAL COMPUTER SYSTEMS, INC. Plaintiff, v. INTERWOVEN, INC., LG ELECTRONICS MOBILECOMM U.S.A., INC., LG ELECTRONICS INC., SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., Defendants. CIVIL ACTION NO. 2:10-cv-490 (Eastern District of Texas)

LG ELECTRONICS DEFENDANTS' THIRD AGREED MOTION FOR EXTENSION OF TIME TO RESPOND TO THE COMPLAINT Defendants LG Electronics Mobilecomm U.S.A., Inc. and LG Electronics Inc. ("LG Defendants"), without waiving any defenses described or referred to in Federal Rule 12, move to extend the time to object to, respond to, move, or otherwise answer Vertical Computer Systems, Inc.'s ("Vertical") complaint to and including May 20, 2011. This motion is not made for delay, but only to permit orderly resolution of issues in the case. Wherefore, the LG Defendants respectfully request that the Court extend the time to object to, respond to, move, or otherwise answer the complaint until May 20, 2011.

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Respectfully submitted, /s/ David J. Healey David J. Healey State Bar No. 09327980 Fish & Richardson P.C. 1221 McKinney, Suite 2800 Houston, Texas 77010 713-654-5300 ­ Telephone [phone] ­ Facsimile [e-mail] ATTORNEYS FOR DEFENDANTS LG ELECTRONICS MOBILECOMM U.S.A., INC. and LG ELECTRONICS INC. OF COUNSEL: Michael J. McKeon Fish & Richardson P.C. 1425 K Street, NW, 11th Floor Washington, DC 20005 202-783-5070 ­ Telephone [phone] ­ Facsimile [e-mail]

CERTIFICATE OF CONFERENCE I certify that I conferred with opposing counsel on this motion and it is agreed to by both Plaintiff and the LG Defendants. /s/ David J. Healey David J. Healey

CERTIFICATE OF SERVICE I hereby certify that on April 7, 2011, the foregoing document was electronically filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel of record who are deemed to have consented to electronic service per Local Rule CV5(a)(3). /s/ Stacci H. Mahadeo Stacci H. Mahadeo