Klausner Technologies Inc v. Verizon Wireless et al

Filing 137

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

Klausner Technologies Inc v. Verizon Wireless et al

Doc. 137

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 NINTH 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 July 13, 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 July 13, 2009. This ninth request for an extension of time is not for delay but for good cause and so that justice may be served.

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

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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: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] ATTORNEYS FOR DEFENDANT EMBARQ COMMUNICATIONS, INC.

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 19, 2009 I electronically filed the foregoing: EMBARQ COMMUNICATIONS, INC.'S NINTH 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 NINTH UNOPPOSED MOTION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT

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