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

Filing 497

Unopposed MOTION for Extension of Time to File Serve Initial Disclosure by LG Electronics USA, Inc.. (Attachments: #1 Text of Proposed Order)(Cornelius, William)

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

Doc. 497

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC, Plaintiff, v. ADIDAS AMERICA, INC., et al, Defendants. ) ) ) ) ) ) ) ) )

Case No. 6:10­cv­491- LED

LG ELECTRONICS USA, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE INITIAL DISCLOSURE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, LG Electronics USA, Inc. ("LGE"), a Defendant herein, by and through counsel, and files this unopposed motion to extend the deadline for serving its initial disclosure, and would show the Court as follows: 1. Under the agreed to, but not yet entered, Discovery Order, the deadline for serving initial

disclosure is March 4, 2011. 2. Defendant LGE has requested, and Plaintiff Parallel Networks has agreed to, an extension

of LGE's deadline to March 11, 2011. 3. The granting of the agreed extension will not prejudice any party and will not otherwise

affect any date or deadline in either the Discovery Order or the Docket Control Order. WHEREFORE PREMISES CONSIDERED, Defendant LG Electronics USA, Inc. prays the Court to grant this motion and to enter an order extending its time to serve initial disclosure to March 11, 2011.

Dockets.Justia.com

Dated: March 4, 2011

Respectfully submitted, /s/ William J. Cornelius, Jr. William J. Cornelius, Jr. Texas Bar No. 04834700 [e-mail] Jennifer Parker Ainsworth State Bar No. 00784720 [e-mail] WILSON, ROBERTSON & CORNELIUS, P.C. 909 ESE Loop 323, Suite 400 Tyler, Texas 75701 (903) 509­5000 Steven Lieberman Brian Tollefson Joo Mee Kim ROTHWELL, FIGG, ERNST & MANBECK, P.C. 1425 K. Street, NW, Suite 800 Washington, DC 20005 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR DEFENDANT LG ELECTRONICS U.S.A., INC. CERTIFICATE OF SERVICE

The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who have consented to electronic service, Local Rule CV-5(a)(3), on March 4, 2011. /s/ William Cornelius___ William Cornelius

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