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

Filing 89

Unopposed MOTION for Extension of Time to File Response/Reply as to 87 Response in Opposition to Motion,,, by LG Electronics Inc. (Attachments: # 1 Text of Proposed Order)(Healey, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
VERTICAL COMPUTER SYSTEMS, INC.
Plaintiff,
v.
CIVIL ACTION NO. 2:10-CV-490
LG ELECTRONICS MOBILECOMM U.S.A.,
INC., LG ELECTRONICS, INC., SAMSUNG
ELECTRONICS CO., LTD., SAMSUNG
ELECTRONICS AMERICA, INC.

JURY

Defendants.

DEFENDANT LG ELECTRONICS MOBILECOMM U.S.A., INC. and LG
ELECTRONICS, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE ITS REPLY TO PLAINTIFF VERTICAL’S RESPONSE IN OPPOSITION TO
LGE’S MOTION TO SEVER AND TRANSFER
Defendants LG Electronics Mobilecomm U.S.A, Inc. and LG Electronics, Inc. (together,
“LGE”) file this unopposed motion for extension of time to file its reply to Plaintiff Vertical’s
Response in Opposition to LGE’s Motion to Sever and Transfer (“Reply to Vertical’s Response
in Opposition”). LGE respectfully requests a short extension of time to and including August 23,
2012, for its Reply to Vertical’s Response in Opposition. LGE conferred with counsel for
Plaintiff, and Plaintiff has agreed to the requested extension of time.
This is the first motion for extension of time for this reply. It is made due to pressing
commitments of counsel and not for the purpose of delay. The extension is only for three
business days after the original due date (August 20, 2012), and the reply will be filed sooner if
practical to do so.

WHEREFORE, LGE respectfully moves the Court to extend the time for LGE to file its
Reply to Plaintiff Vertical’s Response in Opposition to LGE’s Motion to Sever and Transfer to
and including August 23, 2012.

Dated: August 16, 2012

Respectfully submitted,
By: /s/ David J. Healey
David J. Healey
State Bar No. 09327980
Fish & Richardson P.C.
1221 McKinney, Suite 2800
Houston, TX 77010
713-654-5300 – Telephone
713-652-0109 – Facsimile
[e-mail]
OF COUNSEL:
Kevin Su
MA Bar No. 663726
Fish & Richardson P.C.
One Marina Park Drive
Boston, MA 02210-1878
617-542-5070 – Telephone
617-542-8906 – Facsimile
[e-mail]
Michael J. McKeon
Fish & Richardson P.C.
1425 K Street, NW, 11th Floor
Washington, DC 20005
202-783-5070 – Telephone
202-783-2331 – Facsimile
[e-mail]

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on August 16, 2012, a true and correct copy of this
document was filed and served on all counsel of record through the Eastern District of Texas’
CM/ECF system.

By: /s/ David J. Healey

CERTIFICATE OF CONFERENCE
The undersigned hereby certifies that the parties have complied with the meet and confer
requirements in Local Rule CV-7(h). Counsel for Plaintiff and LGE have conferred regarding the
relief requested herein, and are in agreement that the relief is unopposed.
By: /s/ David J. Healey