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)

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.

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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: [e-mail]
Daniel M. Wall
California State Bar No. 102580
Email: [e-mail]
Brendan A. McShane
California State Bar No. 227501
Email: [e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111-6538
Telephone: [phone]
Facsimile: [phone]
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and
John J. Little
Texas State Bar No. 12424230
Email: [e-mail]
LITTLE PEDERSEN FANKHAUSER LLP
901 Main Street, Suite 4110
Dallas, TX 75202-3714
Telephone: [phone]
Facsimile: [phone]
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

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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

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