American Airlines Inc v. Travelport Limited et al

Filing 387

Unopposed Motion for Extension of Time to File Answer to the Second Amended Complaint filed by Orbitz Worldwide, LLC (Attachments: #1 Proposed Order) (Yates, Christopher)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION AMERICAN AIRLINES, INC., a Delaware corporation, Plaintiff, vs. TRAVELPORT LIMITED, a foreign corporation, and TRAVELPORT, LP, a Delaware limited partnership, d/b/a TRAVELPORT; SABRE, INC., a Delaware corporation; SABRE HOLDINGS CORPORATION, a Delaware corporation and SABRE TRAVEL INTERNATIONAL LTD., a foreign corporation, d/b/a SABRE TRAVEL NETWORK; and ORBITZ WORLDWIDE, LLC, a Delaware limited liability company, d/b/a ORBITZ, Defendants. § § § § § § § § § § § § § § § § § § § § § § § § § Civil Action No. 4:11-cv-00244-Y ORBITZ WORLDWIDE, LLC’S UNOPPOSED MOTION TO EXTEND THE TIME BY WHICH IT MUST ANSWER THE SECOND AMENDED COMPLAINT Defendant Orbitz Worldwide, LLC (“Orbitz”), through its undersigned counsel, hereby files this unopposed motion to extend the time by which it must answer plaintiff American Airlines, Inc.’s Second Amended Complaint, and in support thereof states as follows: 1. On or about December 5, 2011, American Airlines, Inc. (“American”) filed its Second Amended Complaint (Doc. 161). On or about December 22, 2011, Orbitz filed a motion to dismiss the Second Amended Complaint (Doc. 165). On August 7, 2012, the Court entered an order denying, among others, Orbitz’s motion to dismiss the Second Amended Complaint. 2. Pursuant to Fed. R. Civ. P. 12(a)(4)(A), Orbitz’s answer to American’s Second Amended Complaint is presently due on August 21, 2012. 3. Orbitz respectfully requests that the Court extend the time by which it must answer the Second Amended Complaint from August 21, 2012 until September 21, 2012. 4. American agrees to the extension of time requested herein. The extension requested by this motion will not impact any other case management deadlines presently set in this action. Accordingly, Orbitz respectfully requests an Order extending its deadline to answer the Second Amended Complaint to and including September 21, 2012. Dated: August 17, 2012 Respectfully submitted, s/ Christopher S. Yates Christopher S. Yates California State Bar No. 161273 Email: Chris.Yates@lw.com Daniel M. Wall California State Bar No. 102580 Email: Dan.Wall@lw.com Brendan A. McShane California State Bar No. 227501 Email: Brendan.McShane@lw.com LATHAM & WATKINS LLP 505 Montgomery Street, Suite 2000 San Francisco, CA 94111-6538 Telephone: (415) 391-0600 Facsimile: (415) 395-8095 1 and John J. Little Texas State Bar No. 12424230 Email: jlittle@jpf-law.com LITTLE PEDERSEN FANKHAUSER LLP 901 Main Street, Suite 4110 Dallas, TX 75202-3714 Telephone: (214) 573-2300 Facsimile: (214) 573-2323 ATTORNEYS FOR DEFENDANT ORBITZ WORLDWIDE, LLC CERTIFICATE OF CONFERENCE Pursuant to Local Rule 7.1(h), undersigned counsel for Defendant Orbitz Worldwide, LLC certifies that counsel for Plaintiff has been consulted and that counsel for Plaintiff does not oppose the relief sought in this motion. s/ Christopher S. Yates Christopher S. Yates 2 CERTIFICATE OF SERVICE On August 17, 2012, I electronically submitted 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/ Christopher S. Yates Christopher S. Yates 3

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