Klausner Technologies Inc v. Verizon Wireless et al

Filing 131

Unopposed MOTION for Extension of Time to File Answer Seventh Unopposed Motion to Extend Time to Answer or Otherwise Respond to Plaintiff's Complaint by Embarq Communications Inc. (Attachments: # 1 Text of Proposed Order Order Granting Embarq's 7th Unopposed Motion for Extension)(Nelson, Mark)

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Klausner Technologies Inc v. Verizon Wireless et al Doc. 131 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 SEVENTH 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 Plaintiff's Complaint until May 20, 2009, and would respectfully show the Court as follows: Embarq requested and Plaintiff agreed to extend the deadline to answer or otherwise respond to the Plaintiff's Complaint up to and including May 20, 2009. This seventh request for an extension of time is not for delay but for good cause and so that justice may be served. A proposed Order granting this unopposed motion is attached for the Court's convenience. EMBARQ'S SEVENTH UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT 1. Dockets.Justia.com Respectfully submitted, __/s/Mark C. Nelson __________ Mark C. Nelson (Lead Attorney) Texas State Bar No. 00793361 Christopher W. Reynolds Texas State Bar No. 24051247 Sonnenschein Nath & Rosenthal LLP 2000 McKinney Ave, Suite 1900 Dallas, Texas 75201 Telephone: (214) 259-0901 Facsimile: (214) 259-0910 Email: mcnelson@sonnenschein.com creynolds@sonnenschein.com ATTORNEYS FOR DEFENDANT EMBARQ COMMUNICATIONS, INC. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 17, 2009 I electronically filed the foregoing: EMBARQ COMMUNICATIONS, INC.'S SEVENTH 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 14792768 EMBARQ'S SEVENTH UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT 2.

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