Chang et al v. Virgin Mobile USA LLC et al

Filing 25

Unopposed MOTION for Extension of Time to File Scheduling Proposal by Susan Chang, Justin Ho-Wee Wong (Zehl, Ryan)

UNITED STATES DISTRICT COURT NORTHER DISTRICT OF TEXAS DALLAS DIVISION SUSAN CHANG, as Next Friend of Alison Chang, a minor, And Justin Ho-Wee Wong Plaintiffs, v. Virgin Mobile Pty Ltd., Defendant. § § § § § § § § § § § § §

CAUSE NO. 3:07-CV-01767

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE SCHEDULING PROPOSAL Plaintiffs respectfully request that the Court extend the deadline to file the Parties' Scheduling Proposal for a period of sixty days until Friday, February 15, 2008. This extension is requested because the only remaining Defendant, Virgin Mobile Pty, Ltd., is not required to file an answer or otherwise respond to Plaintiffs' claims until December 20, 2007. It is not until after this time that the parties will be able to meaningfully discuss a potential resolution or any of the other issues addressed in Section IV of this Court's Order for a Proposed Scheduling Order. The parties believe that this sixty-day extension will provide them with adequate time to meet, confer and craft a mutually agreeable plan.

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Respectfully submitted, /s/ Ryan H. Zehl____________________ Ryan H. Zehl State Bar No. 24047166 Fitts Zehl, LLP 5065 Westheimer Rd., Suite 700 Houston, Texas 77056 [phone] (telephone) [phone] (facsimile) [e-mail] Mark W. Romney State Bar No. 17225750 Shannon, Gracey, Ratliff & Miller, LLP 500 N. Akard Street, Suite 2500 Dallas, Texas 75201 [phone] (telephone) [phone] (facsimile) [e-mail] ATTORNEYS FOR PLAINTIFFS

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CERTIFICATE OF CONFERENCE I certify, pursuant to Local Rule 7.1, that I conferred with Lisa Meyerhoff, counsel for Defendant Virgin Mobile Pty, Ltd. on November 27, 2007 and that she consented to the parties' Joint Motion to Extend the Deadline to File a Scheduling Proposal. /s/ Ryan H. Zehl__________ Ryan H. Zehl

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CERTIFICATE OF SERVICE I hereby certify that on the 28 day of November, 2007, I electronically filed the foregoing document with the Clerk of the Court for the U.S. District Court, Northern District of Texas, using the Court's electronic case filing system. The system sent a "Notice of Electronic Filing" to the following attorneys of record, all of whom have consented to accept this Notice as service of the document: Lisa H. Meyerhoff Baker & McKenzie LLP 2001 Ross Ave. Dallas, Texas 75201

/s/ Ryan H. Zehl______________________ Ryan H. Zehl

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