American Airlines Inc v. Travelport Limited et al

Filing 12

Unopposed Motion for Extension of Time to File Answer to Plaintiff's Complaint filed by Travelport Limited, Travelport, LP (Friedman, Walker)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
AMERICAN AIRLINES, INC.,
Plaintiff,
vs.
TRAVELPORT LIMITED, a foreign
corporation, and TRAVELPORT, LP,
a Delaware limited partnership, d/b/a
TRAVELPORT;
and
ORBITZ WORLDWIDE, LLC,
a Delaware limited liability company,
d/b/a ORBITZ,
Defendants.

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Civil Action No. 4:11-cv-00244-Y

TRAVELPORT LIMITED AND TRAVELPORT, LP’S
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendants TRAVELPORT LIMITED and TRAVELPORT, LP (collectively, the
“TRAVELPORT DEFENDANTS”) hereby file this Unopposed Motion for Extension of Time to
Respond to Plaintiff’s Complaint, and in support thereof would respectfully show the Court as
follows:
1.

The TRAVELPORT DEFENDANTS were served with Plaintiff AMERICAN

AIRLINES, INC.’s Complaint [Doc. No. 1] on April 13, 2011.

Accordingly, the

TRAVELPORT DEFENDANTS’ response to Plaintiff’s Complaint is currently due on May 4,
2011.
2.

In order to effectively respond to Plaintiff’s Complaint, the TRAVELPORT

DEFENDANTS respectfully request that the Court extend the time to respond from May 4,

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2011, to May 25, 2011.
3.

Plaintiff agrees to the extension of time requested herein.

WHEREFORE, the TRAVELPORT DEFENDANTS request that the Court grant this
Unopposed Motion for Extension of Time to Respond to Plaintiff’s Complaint and order that the
deadline for the TRAVELPORT DEFENDANTS to respond to Plaintiff’s Complaint is extended
to and including May 25, 2011.
Dated: April 29, 2011.

Respectfully submitted,
/s/ Walker C. Friedman
Walker C. Friedman
State Bar No. 07472500
[e-mail]
Christian D. Tucker
State Bar No. 00795690
[e-mail]
FRIEDMAN, SUDER & COOKE, P.C.
Tindall Square Warehouse No. 1
604 East 4th Street, Suite 200
Fort Worth, Texas 76102
817.334.0400
817.334.0401 (Fax)
ATTORNEYS FOR DEFENDANTS
TRAVELPORT LIMITED and
TRAVELPORT, LP

Of Counsel to Travelport Defendants:
Michael L. Weiner
[e-mail]
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036-6797
212.698.3608
212.698.3599 (Fax)
Mike Cowie
[e-mail]
Craig Falls
[e-mail]

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Dechert LLP
1775 I Street, NW
Washington, D.C. 20006-2401
202.261.3300
202.261.3333 (Fax)
John T. Schriver
[e-mail]
Paul E. Chronis
[e-mail]
Duane Morris LLP
Suite 3700
190 South LaSalle Street
Chicago, Illinois 60603-3433
312.499.6700
312.499.6701 (Fax)

CERTIFICATE OF CONFERENCE
I hereby certify that on the 28th day of April, 2011, I conferred with counsel for Plaintiff,
including Bill Bogle and Paul Yetter, regarding the merits of this Motion by emailing a draft of it
to them and requesting whether or not they were opposed to the relief requested herein. On April
28, 2011, Mr. Bogle informed my co-counsel, Walker C. Friedman, via email that Plaintiff is
unopposed to this Motion.

/s/ Christian D. Tucker
Christian D. Tucker
CERTIFICATE OF SERVICE
I hereby certify that on the 29th day of April, 2011, I electronically filed the foregoing
document with the clerk of the court for the U.S. District Court, Northern District of Texas, Fort
Worth Division, using the electronic case filing system of the court. The electronic case filing
system sent a “Notice of Electronic Filing” to the attorneys of record who have consented in
writing to accept this Notice as service of this document by electronic means.

/s/ Christian D. Tucker
Christian D. Tucker

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