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

Filing 78

Unopposed MOTION for Extension of Time to File Answer re #1 Complaint,,,,,,, by General Motors LLC. (Attachments: #1 Text of Proposed Order)(Jones, Michael)

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

Doc. 78

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC v. ADIDAS AMERICA, INC., ET AL § § § § §

CIVIL ACTION NO. 6:10-cv-491 JURY TRIAL DEMANDED

DEFENDANT GENERAL MOTORS LLC'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendant General Motors LLC (hereinafter referred to as "GM"), without waiving any defenses or any matters that might be presented pursuant to FEDERAL RULE OF CIVIL PROCEDURE 12(b) or any other rule or law, files their unopposed motion for extension of time in which to answer, move, or otherwise respond to Plaintiff Parallel Networks, LLC's Complaint and would respectfully show the Court as follows: GM has requested and Plaintiff has agreed that in exchange for the requested extension, GM has agreed to waive requirements for formal service of process and accepts service through counsel for GM. Plaintiff has agreed to an extension of GM's time to respond in any manner whatsoever including answer, motion or other pleading of any type to Plaintiff's Complaint. Specifically, GM requests, and Plaintiff does not oppose, an extension of time up to and including November 8, 2010. A proposed Order granting this unopposed motion is attached for the Court's convenience. Dated: October 7, 2010 Respectfully submitted, By: /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 Allen F. Gardner State Bar No. 24043679
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Dockets.Justia.com

POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P. O. Box 359 Tyler, Texas 75710 [phone] [phone] (Facsimile) [e-mail] [e-mail] Edward H. Rice LOEB & LOEB LLP 321 North Clark Street Suite 2300 Chicago, IL 60654 Tel: [phone] Fax: [phone] [e-mail] ATTORNEYS FOR DEFENDANT GENERAL MOTORS LLC CERTIFICATE OF SERVICE I hereby certify that all counsel of record who 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 October 7, 2010. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Michael E. Jones Michael E. Jones

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