Mirror Worlds, LLC v. Apple, Inc.

Filing 126

Unopposed MOTION for Extension of Time to File Response/Reply as to #113 Answer to Complaint, Counterclaim by Mirror Worlds Technologies, Inc., Mirror Worlds, LLC. (Attachments: #1 Text of Proposed Order)(An, Richard)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 126

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, JURY TRIAL DEMANDED v. APPLE, INC. Defendant. APPLE, INC. Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS, TECHNOLOGIES, INC. Counterclaim Defendants. UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO APPLE, INC.'S SECOND AMENDED ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIMS Counterclaim Defendants Mirror Worlds, LLC and Mirror Worlds Technologies, Inc. hereby move the Court for a ten-day extension of time to answer, or otherwise respond to, the Second Amended Answer, Affirmative Defenses and Counterclaims of Counterclaim Plaintiff Apple, Inc. ("Apple") (Dkt. 113). With the extension, Mirror Worlds, LLC and Mirror Worlds Technologies, Inc. would have until September 25, 2009 to answer, or otherwise respond to, Apple's Second Amended Answer, Affirmative Defenses and Counterclaims. Apple does not oppose this Motion. This extension is not sought for purposes of delay. Civil Action No. 6:08-CV-88 LED

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WHEREFORE, Mirror Worlds, LLC and Mirror Worlds Technologies, Inc. respectfully request the Court grant the aforementioned Unopposed Motion for extension of time.

Respectfully submitted, BY: /s/ Richard H. An Otis Carroll, Lead Counsel (Texas States Bar No. 03895700) Deborah Race (Texas State Bar No. 16448700) IRELAND CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: [phone] Fax: [phone] Email: [e-mail] Joseph Diamante (Pro Hac Vice) Kenneth L. Stein (Pro Hac Vice) Richard H. An (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, N.Y. 10038 Tel: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] ATTORNEYS FOR MIRROR WORLDS, LLC AND MIRROR WORLDS TECHNOLOGIES, INC.

CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document this 14th day of September, 2009, via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Richard H. An