Aloft Media, LLC v. Oracle Corporation et al

Filing 71

Unopposed MOTION for Extension of Time to File Answer re 43 Amended Complaint, Motion for Extension of Time to Answer, Move or Otherwise Respond to Second Amended Complaint by E-Trade Securities, LLC, Charles Schwab & Co., Inc., Fidelity Brokerage Services, LLC, TD Ameritrade, Inc.. (Attachments: # 1 Text of Proposed Order)(Race, Deborah)

Case 6:09-cv-00304-LED Document 71

Filed 03/05/10 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ALOFT MEDIA, LLC VS. ORACLE CORPORATION, ET AL § § § § §

CIVIL ACTION NO. 6:09-CV-304 JURY DEMANDED

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE OR OTHERWISE RESPOND Defendants Charles Schwab & Co, Inc., Fidelity Brokerage Services, LLC, E-Trade Securities, LLC and TD Ameritrade, Inc. file this unopposed motion seeking an extension of time within which to answer, move or otherwise respond to Plaintiff's Second Amended Complaint for Patent Infringement in the above-referenced cause up to and including until March 19, 2010. Accordingly, Defendants Charles Schwab & Co, Inc., Fidelity Brokerage Services,

LLC, E-Trade Securities, LLC and TD Ameritrade, Inc. respectfully request that the Court enter an order extending their time to answer, move or otherwise respond to Plaintiff's Second Amended Complaint for Patent Infringement until March 19, 2010. An order reflecting the relief requested is attached for the Court's convenience. Respectfully submitted, DATE: March 5, 2010 BY: /s/ Deborah Race Otis Carroll State Bar No. 03895700 Deborah Race State Bar No. 16448700 IRELAND, CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Telephone:[phone] Facsimile: [phone] [e-mail]

Case 6:09-cv-00304-LED Document 71

Filed 03/05/10 Page 2 of 2

ATTORNEYS FOR DEFENDANTS CHARLES SCHWAB & CO, INC., FIDELITY BROKERAGE SERVICES, LLC, E-TRADE SECURITIES, LLC and TD AMERITRADE, INC.

CERTIFICATE OF CONFERENCE I certify that on counsel for Defendants Charles Schwab & Co, Inc., Fidelity Brokerage Services, LLC, E-Trade Securities, LLC and TD Ameritrade, Inc. conferred with counsel for

Plaintiff, Eric Albritton, who agreed to Defendants' request for an extension of time to answer or otherwise respond to Plaintiff's Second Amended Complaint. /s/ Deborah Race Deborah Race

CERTIFICATE OF SERVICE The undersigned hereby certifies 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). Any other counsel of record will be served by facsimile transmission and/or first class mail this 5th day of March, 2010.

/s/ Deborah Race Deborah Race