Mirror Worlds, LLC v. Apple, Inc.

Filing 61

Unopposed MOTION for Extension of Time to File Response/Reply as to 56 MOTION for Leave to File First Amended Answer, Affirmative Defenses, and Counterclaims by Mirror Worlds, LLC. (Attachments: # 1 Text of Proposed Order)(Carroll, Otis)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 61 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED v. APPLE, INC. Defendant. PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT'S MOTION FOR LEAVE TO FILE FIRST AMENDED ANSWER, AFFIRMATIVE DEFENSES, AND COUNTERCLAIMS Plaintiff respectfully moves the Court for an extension of time to respond to Defendant's Motion for Leave to File First Amended Answer, Affirmative Defenses, and Counterclaims (Dkt. # 56). Pursuant to Local Rule CV-7(e), Plaintiff's response is currently due January 8, 2009. To allow Plaintiff sufficient time to fully address the issues raised in the motion, and because of the intervening holidays, Plaintiff requested and Defendant agreed to an extension of time until January 16, 2009, to respond to the motion. Accordingly, Plaintiff requests that the Court extend the deadline to respond to Defendant's Motion until January 16, 2009. An order reflecting the relief requested herein is attached for the Court's convenience. Dockets.Justia.com Respectfully submitted, BY: /s/ Otis Carroll_____________ Otis Carroll, Lead Counsel Texas State Bar No. 03895700 Deborah Race Texas State Bar No. 16448700 IRELAND CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600 Fax: (903) 581-1071 Email: Fedserv@icklaw.com OF COUNSEL: Joseph Diamante Kenneth L. Stein Richard H. An JENNER & BLOCK LLP 919 Third Avenue, 37th Floor New York, New York 10022-3908 Tel: (212) 891-1600 Fax: (212) 891-1699 Email: kstein@jenner.com Email: ran@jenner.com ATTORNEYS FOR PLAINTIFF, MIRROR WORLDS, LLC CERTIFICATE OF CONFERENCE The undersigned certifies that Plaintiff's counsel corresponded with Defendant's counsel, Nicholas Brown, on January 2, 2008 regarding the filing of this motion and Defendant is not opposed to the relief requested herein. /s/ Otis Carroll 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 5th day of January, 2009, via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Otis Carroll_________________

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