Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 374

Unopposed MOTION for Extension of Time to Complete Discovery for an Extension for Service of P.R. 3-1 and 3-2 Disclosures by Parallel Networks, LLC. (Attachments: #1 Text of Proposed Order)(Tadlock, Charles)

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Parallel Networks, LLC v. Adidas America, Inc. et al Doc. 374 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC, Plaintiff, v. ADIDAS AMERICA, INC., et al. Defendants. UNOPPOSED MOTION FOR AN EXTENSION FOR SERVICE OF P.R. 3-1 AND 3-2 DISCLOSURES Plaintiff, Parallel Networks, LLC, ("Parallel Networks") respectfully moves this Court for a 14-day extension to serve its P.R. 3-1 and 3-2 disclosures. Defendants do not oppose the motion. In support of its motion Parallel Networks states as follows: 1. On December 9, 2010, the Court entered an order setting a status conference for No. 6:10-cv-00491-LED Jury Trial Demanded January 4, 2010, and further stating that Plaintiff's P.R. 3-1 and 3-2 disclosures will be due four days after the status conference. Due to the due date falling on a weekend, Plaintiff's P.R. 3-1 and 3-2 disclosures are currently due January 10, 2011. 2. Due to the holidays, Parallel Networks requests a 14 day extension, to January 24, 2011, to serve its P.R. 3-1 and 3-2 disclosures. In exchange for not opposing the motion, Parallel Networks has agreed with the defendants that when agreeing to a schedule, Parallel Networks will agree to a 14-day extension to the due dates proposed in the Court's standard docket control and discovery order for: defendants' to serve their P.R. 3-3 and 3-4 disclosures; the deadline for initial disclosures; and the start of the document production pursuant to paragraph 2(A) of Judge Davis's Proposed Discovery Order. 3. Defendants do not oppose this motion. 1 For the foregoing reasons, Parallel Networks respectfully requests that the Court extend the deadline to serve P.R. 3-1 and 3-2 disclosures until and including January 24, 2011. Dated: December 14, 2010 Respectfully submitted, By: /s/ Charles Craig Tadlock Charles Craig Tadlock Texas State Bar No. 00791766 TADLOCK LAW FIRM 400 E. Royal Lane, Suite 290 Irving, Texas 75039 Telephone: (214) 785-6014 and 315 N. Broadway, Suite 307 Tyler, Texas 75702 Telephone: (903) 283-2758 George S. Bosy (pro hac vice) David R. Bennett (pro hac vice) Bosy & Bennett 300 N. La Salle St. 49th Floor Chicago, IL 60654 Telephone: (312) 803-0437 Email: ATTORNEYS FOR PLAINTIFF PARALLEL NETWORKS, LLC CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 14th day of December, 2010, 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 electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Charles Craig Tadlock One of the Attorneys for Parallel Networks, LLC 2

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