EMG Technology, LLC v. Apple, Inc.

Filing 42

Agreed MOTION for Extension of Time to File Answer re 29 Amended Complaint, for CONTINENTAL AIRLINES, INC. by EMG Technology, LLC. (Attachments: # 1 Text of Proposed Order)(Ainsworth, Charles)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

EMG TECHNOLOGY, LLC, Plaintiff, v. APPLE, INC., AMERICAN AIRLINES, INC., BLOOMBERG, L.P., CONTINENTAL AIRLINES, INC., UNITED PARCEL SERVICE, INC., Defendants. CASE NO. 6:08-cv-447

JURY TRIAL DEMANDED

AGREED MOTION FOR EXTENSION OF TIME FOR CONTINENTAL AIRLINES, INC. TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT Plaintiff, EMG TECHNOLOGY, LLC, files this Agreed Motion for Extension of Time for Defendant, CONTINENTAL AIRLINES, INC., to answer or otherwise respond to Plaintiff's Second Amended Complaint and in support of same would show the Court as follows: Defendant CONTINENTAL AIRLINES, INC.'s deadline to answer or otherwise respond was previously extended to March 16, 2009. The parties respectfully request an additional extension of time for Defendant, CONTINENTAL AIRLINES, INC., to file its answer or otherwise respond to Plaintiff's Second Amended Complaint up to and including March 31, 2009.

DATED: March 12, 2009 OF COUNSEL: Jeffer, Mangels, Butler and Marmaro, LLP Stanley M. Gibson (Cal. Bar No. 162329) [e-mail] Brian W. Kasell (Cal. Bar No. 143776) [e-mail] Joshua S. Hodas, Ph.D. (Cal. Bar No. 250812) [e-mail] 1900 Avenue of the Stars, Seventh Floor Los Angeles, CA 90067 Telephone: [phone] Facsimile: [phone] Manatt, Phelps & Phillips, LLP Robert D. Becker (Cal. Bar No. 160648) [e-mail] 1001 Page Mill Road, Building 2 Palo Alto, CA 94304 Telephone: [phone] Facsimile: [phone]

Respectfully Submitted, By: Charles Ainsworth Charles Ainsworth State Bar No. 00783521 Robert Christopher Bunt State Bar No. 00787165 PARKER, BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, TX 75702 903/531-3535 903/533-9687 E-mail: [e-mail] E-mail: [e-mail]

CERTIFICATE OF SERVICE I hereby certify that all counsel of record, who are deemed to have consented to electronic service are being served this 12th day of March, 2009, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Charles Ainsworth Charles Ainsworth

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