Klausner Technologies Inc v. Verizon Wireless et al

Filing 101

Unopposed MOTION for Extension of Time to File Answer or Otherwise Respond to Plaintiff's Complaint (Third) by Embarq Communications Inc. (Attachments: # 1 Text of Proposed Order)(Nelson, Mark)

Klausner Technologies Inc v. Verizon Wireless et al

Doc. 101

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION KLAUSNER TECHNOLOGIES, INC., Plaintiff, v. VERIZON WIRELESS (CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS), et al., Defendants. ) ) ) Civil Action No. 6:08-CV-00341-LED ) ) JURY TRIAL DEMANDED ) ) ) ) ) )

EMBARQ COMMUNICATIONS, INC.'S THIRD UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendant Embarq Communications, Inc. ("Embarq") moves the Court to extend the deadline to answer or otherwise respond to the Original complaint until January 17, 2009. The original Complaint was filed on August 26, 2008. Plaintiff Klausner Technologies, Inc. and Embarq agreed to extend the deadline to answer or otherwise respond to the Original Complaint to December 17, 2008. This third request for an extension of time is not for delay but for good cause and so that justice may be served. WHEREFORE, Embarq requests that this Court extend the deadline to answer or otherwise respond to the Original Complaint to January 17, 2009.

EMBARQ'S THIRD UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT

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Dockets.Justia.com

Respectfully submitted, __/s/Mark C. Nelson ___________ Mark C. Nelson (Lead Attorney) Texas State Bar No. 00793361 Darin W. Deaver Texas State Bar No. 24040779 Christopher W. Reynolds Texas State Bar No. 24051247 Sonnenschein Nath & Rosenthal LLP 1717 Main Street, Suite 3400 Dallas, Texas 75201-7395 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] ATTORNEYS FOR DEFENDANT EMBARQ COMMUNICATIONS, INC.

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 16, 2008 I electronically filed the foregoing: EMBARQ COMMUNICATIONS, INC.'S THIRD UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT with the Clerk of the Court by using the CM/ECF System which will serve all counsel of record by notice of electronic filing, pursuant to Fed. R. Civ. P. 5(b)(2)(D). /s/Mark C. Nelson Mark C. Nelson

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EMBARQ'S THIRD UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT

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