Lodsys, LLC v. Combay, Inc. et al
Unopposed MOTION for Extension of Time to File Answer re 26 Amended Complaint, or Otherwise Respond by Michael G. Karr d/b/a Shovelmate. (Attachments: # 1 Text of Proposed Order)(Findlay, Eric)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
CIVIL ACTION NO. 2:11-cv-272-TJW
COMBAY, INC., et al.,
MICHAEL G. KARR D/B/A SHOVELMATE’S UNOPPOSED MOTION TO EXTEND
TIME TO MOVE, ANSWER, OR OTHERWISE RESPOND TO PLAINTIFF’S
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, Defendant Michael G. Karr d/b/a Shovelmate, without waiving any defenses
described or referred to in Rule 12 F.R.C.P., and moves the Court to extend the time within which
Michael G. Karr d/b/a Shovelmate is required to move, answer, or otherwise respond to Plaintiff’s
Complaint to and including September 21, 2011.
Counsel for Plaintiff, Lodsys, LLC, is unopposed to this request.
Michael G. Karr d/b/a Shovelmate seeks this extension of time not for delay but for good
cause so that justice may be served.
WHEREFORE, Michael G. Karr d/b/a Shovelmate respectfully prays that the time to move,
answer, or otherwise respond to Plaintiff’s Complaint be extended to and including September 21,
Dated: August 19, 2011
By: /s/ Eric H. Findlay
Eric H. Findlay
Texas Bar No. 00789886
Texas Bar No. 04972020
FINDLAY CRAFT, LLP
6760 Old Jacksonville Hwy
Tyler, TX 75703
Telephone: (903) 534-1100
Facsimile: (903) 534-1137
Counsel for Defendant Michael G. Karr d/b/a
CERTIFICATE OF SERVICE
The undersigned certifies that on August 19, 2011, the foregoing document was filed
electronically in compliance with Local Rule CV-5(a). This motion was served on all counsel by
/s/ Eric H. Findlay
Eric H. Findlay
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