Aloft Media, LLC v. Oracle Corporation et al

Filing 56

Agreed MOTION for Extension of Time to File Answer re 43 Amended Complaint, by SAP AG, SAP America, Inc. (Attachments: # 1 Text of Proposed Order re Agreed Motion to Extend Time To File Answer)(Healey, David)

Aloft Media, LLC v. Oracle Corporation et al

Doc. 56

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ALOFT MEDIA, LLC Plaintiff, v. ORACLE CORPORATION, et al., Defendants. § § § § § § § § § § §

CIVIL ACTION NO. 6:09-CV-304 (LED)

AGREED MOTION OF SAP AG AND SAP AMERICA, INC. FOR EXTENSION OF TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendants SAP AG and SAP America, Inc. ("SAP") file this Agreed Motion for Extension of Time to Answer, Move, or Otherwise Respond Plaintiff's Complaint, and would respectfully show the Court as follows: WHEREAS plaintiff Aloft Media, LLC filed its original Complaint on July 14, 2009; WHEREAS plaintiff Aloft Media, LLC filed its First Amended Complaint on November 9, 2009; WHEREAS plaintiff Aloft Media, LLC filed its Second Amended Complaint on December 18, 2009; WHEREAS counsel for SAP agreed to accept service on behalf of SAP on December 18, 2009; WHEREAS SAP requested to extend the deadline to answer, move, or otherwise respond to plaintiff's Complaint until March 9, 2010; and

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WHEREAS the parties have met and conferred, and plaintiff does not oppose this request; WHEREFORE, PREMISES CONSIDERED, SAP respectfully requests that the time to answer, move or otherwise respond to the Complaint be moved to and include March 9, 2010. DATED: December 30, 2009 By: /s/ David J. Healey David J. Healey (Texas Bar No. 09327980) Benjamin C. Elacqua (Texas Bar No. 24055443) Fish & Richardson P.C. One Houston Center ­ 28th Floor 1221 McKinney Houston, TX 77010 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Defendants SAP AG, SAP AMERICA, INC.

AGREED MOTION FOR EXTENSION OF TIME

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CERTIFICATE OF SERVICE This is to certify that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on December 30, 2009. /s/ David J. Healey David J. Healey