American Airlines Inc v. Travelport Limited et al

Filing 453

Unopposed MOTION to Extend Time to Extend Plaintiff's Time to Respond to Defendants' Motion for Reconsideration and Leave to File an Additional Counterclaim filed by American Airlines Inc (Attachments: #1 Proposed Order) (Garcia, Yolanda)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

AMERICAN AIRLINES, INC.,
Plaintiff,
vs.
TRAVELPORT LIMITED, et al.,
Defendants.

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) Case No. 4:11-cv-00244-Y
) (ODD DOCKET LAW CLERK)
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UNOPPOSED MOTION TO EXTEND PLAINTIFF’S TIME TO RESPOND TO
DEFENDANTS’ MOTION FOR RECONSIDERATION AND LEAVE TO FILE AN
ADDITIONAL COUNTERCLAIM
Plaintiff American Airlines, Inc. (“American”) files this unopposed motion to briefly
extend its deadline to respond to Defendants Travelport Limited and Travelport, LP (collectively,
“Travelport”) Motion for Reconsideration and Leave to File an Additional Counterclaim (the
“Motion”) (Dkt. 433) from February 26, 2013 until March 8, 2013. Travelport does not oppose
the requested relief.
American seeks this brief extension because Travelport has moved the United States
Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”) in the case of
In re AMR Corp., et al., Case No. 11-15463(SHL), to modify the automatic stay to allow
Travelport to amend its counterclaims against American in this action. The Bankruptcy Court is
hearing argument on this motion on February 26, 2013, the same day as American’s current
deadline to respond to the Motion. If the Bankruptcy Court denies Travelport’s motion to lift the
stay, it could obviate the need for the parties to brief or the Court to consider some of the issues

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raised in Travelport’s Motion. Accordingly, American requests that Court extend American’s
deadline to respond to Travelport’s Motion from February 26, 2013 until March 8, 2013.
Dated: February 25, 2013

Respectfully submitted,
/s/ Yolanda C. Garcia
Yolanda C. Garcia
State Bar No. 24012457
Michelle Hartmann
State Bar No. 24032401
Robert S. Velevis
State Bar No. 24047032
WEIL, GOTSHAL & MANGES LLP
200 Crescent Court, Suite 300
Dallas, Texas 75201-6950
[phone]
[phone] (Fax)
R. Paul Yetter
State Bar No. 22154200
Anna Rotman
State Bar No. 24046761
YETTER COLEMAN LLP
909 Fannin, Suite 3600
Houston, Texas 77010
[phone]
[phone] (Fax)
Bill F. Bogle
State Bar No. 02561000
Roland K. Johnson
State Bar No. 00000084
HARRIS, FINLEY & BOGLE, P.C.
777 Main Street, Suite 3600
Fort Worth, Texas 76102
[phone]
[phone] (Fax)
ATTORNEYS FOR PLAINTIFF
AMERICAN AIRLINES, INC.

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OF COUNSEL:
Richard A. Rothman (pro hac vice)
Robert Berezin (pro hac vice)
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
[phone]
[phone] (Fax)
MJ Moltenbrey (pro hac vice)
DEWEY & LEBOEUF LLP
1101 New York Avenue, N.W.
Washington, D.C. 20005
[phone]
[phone] (Fax)

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CERTIFICATE OF CONFERENCE
Pursuant to Local Rule 7.1(h), undersigned counsel for American certifies that
counsel for Travelport has been consulted and does not oppose the relief sought in this motion.
/s/ Yolanda C. Garcia
Yolanda C. Garcia

CERTIFICATE OF SERVICE
I hereby certify that on February 25, 2013, a true and correct copy of the
foregoing was filed with the Clerk of this Court using the CM/ECF system, which will serve a
notice of filing upon the filing users.
/s/ Robert Velevis
Robert Velevis

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