AdvanceMe Inc v. RapidPay LLC

Filing 241

MOTION for Extension of Time to File Response/Reply as to 232 SEALED PATENT MOTION for Partial Summary Judgment of Patent Invalidity by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Plaintiff's Unopposed Motion to Extend Deadline to Oppose Defendants' Second Motion for Partial Summary Judgment of Patent Invalidity)(Edelman, Michael)

AdvanceMe Inc v. RapidPay LLC

Doc. 241

Case 6:05-cv-00424-LED

Document 241

Filed 04/23/2007

Page 1 of 3

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

ADVANCEME, INC., Plaintiff, v. RAPIDPAY LLC, FIRST FUNDS LLC, MERCHANT MONEY TREE, INC., REACH FINANCIAL, LLC, and FAST TRANSACT, INC. d/b/a SIMPLE CASH, Defendants.

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CASE NO. 6:05-CV-424 (LED ­ JDL)

PLAINTIFF'S UNOPPOSED MOTION TO EXTEND DEADLINE TO OPPOSE DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT OF PATENT INVALIDITY Plaintiff, AdvanceMe, Inc., respectfully requests this Court for an extension of the deadline to oppose Defendants' Second Motion for Partial Summary Judgment of Invalidity. Specifically, AdvanceMe, Inc. requests that the Court extend its deadline from April 27, 2007 to May 2, 2007. Plaintiff requests the additional time because its counsel will be involved in an office relocation from April 26-April 30, 2007 and because of the unavailability of its lead trial counsel this week due to a mediation, pre-trial conference, and other matters before May 2, 2007. Counsel for AdvanceMe, Inc. has conferred with R. Floyd Walker and Joseph Gray, counsel for Defendants. Defendants have stated that they do not oppose this motion.

MOTION TO EXTEND DEADLINE TO OPPOSE DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT OF PATENT INVALIDITY

CASE NO.6:05-CV-424

Dockets.Justia.com

Case 6:05-cv-00424-LED

Document 241

Filed 04/23/2007

Page 2 of 3

A proposed Order is attached for the Court's convenience. Dated: April 23, 2007 Respectfully submitted, By: ___________/s/ Michael N. Edelman____________ PAUL, HASTINGS, JANOFSKY & WALKER LLP Ronald S. Lemieux (CA Bar No. 120822) (Admitted Pro Hac Vice) Michael N. Edelman (CA Bar No. 180948) (Admitted Pro Hac Vice) Vidya R. Bhakar (CA Bar No. 220210) (Admitted Pro Hac Vice) Robert C. Matz (CA Bar No. 217822) (Admitted Pro Hac Vice) Shanée Y. Williams (CA Bar No. 221319) (Admitted Pro Hac Vice) Five Palo Alto Square, Sixth Floor Palo Alto, CA 94306-2155 Telephone: [phone] Telecopier: [phone] Email: [e-mail] IRELAND, CARROLL & KELLEY, P.C. Otis W. Carroll, Attorney-in-Charge State Bar No. 03895700 Deborah Race State Bar No. 16448700 6101 South Broadway, Suite 500 Tyler, TX 75703 Telephone: [phone] Facsimile: 903-581-1071 Email: [e-mail] ATTORNEYS FOR PLAINTIFF ADVANCEME, INC.

MOTION TO EXTEND DEADLINE TO OPPOSE DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT OF PATENT INVALIDITY

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CASE NO.6:05-CV-424

Case 6:05-cv-00424-LED

Document 241

Filed 04/23/2007

Page 3 of 3

CERTIFICATE OF CONFERENCE The undersigned counsel for AdvanceMe, Inc. has conferred with R. Floyd Walker and Joseph Gray, counsel for Defendants. Defendants have stated that they do not oppose this motion.

/s/ Michael N. Edelman Michael N. Edelman

CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served a copy of this document via the court's CM/ECF system pursuant to Local Rule CV-5(a)(3) on this the 23rd day of April, 2007. Any other counsel of record will be served by first-class mail on this same date. /s/ Michael N. Edelman Michael N. Edelman
LEGAL_US_W # 56083849.1

MOTION FOR EXTENSION TO OPPOSE DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT OF PATENT INVALIDITY

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CASE NO.6:05-CV-424