Dazzlesmile et al v. Epic Advertising et al

Filing 41

Stipulated MOTION for Extension of Time To Answer Plaintiffs' Complaint filed by Defendant Neverblue Media. (Attachments: # 1 Text of Proposed Order)(Marshall, Romaine)

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Romaine C. Marshall (9654) HOLLAND & HART LLP 222 S. Main Street, Suite 2200 Salt Lake City, Utah 84101 Telephone: (801) 799-5800 Facsimile: (801) 799-5700 Donald A. Degnan (appearing pro hac vice) HOLLAND & HART LLP 1800 Broadway, Suite 300 Boulder, Colorado 80302 Telephone: (303) 473-2724 Attorneys for Defendant NeverBlue Media, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION DAZZLESMILE, LLC, a Utah limited liability company, and OPTIMAL HEALTH SCIENCE, LLC, a Utah limited liability company, Plaintiffs, vs. EPIC ADVERTISING, INC., a purported Delaware corporation AKA AZOOGLE.COM, INC., AKA AZOOGLEADS US INC., and AKA EPIC/AZOOGLE; AZOOGLE.COM, INC., a Delaware corporation; AZOOGLEADS US, INC., a non-public Delaware corporation; FAREND SERVICES LIMITED, a Cyprus registered company; JESSE DAVID WILLMS, an individual; 1021018 ALBERTA LTD, a Numbered Alberta Canadian Corporation AKA JUST THINK MEDIA; ATLAST HOLDINGS, INC., a Colorado corporation, d/b/a ATLAST FULFILLMENT; NEVERBLUE MEDIA, INC., a Canadian corporation; GOOGLE, INC., a Delaware corporation; YAHOO! INC., a Delaware corporation; MICROSOFT Civil Action No. 2:09-CV-1043 Magistrate Judge Paul M. Warner STIPULATED MOTION FOR EXTENSION OF TIME TO ANSWER PLAINTIFFS' COMPLAINT CORPORATION, a Washington corporation; and DOES 1-10, Defendants. Pursuant to DUCivR 77-2(a)(4), Defendant NeverBlue Media, Inc. ("NeverBlue"), by and through its counsel, HOLLAND & HART LLP, respectfully submits this Stipulated Motion for Extension of Time to Answer Plaintiffs' Complaint. NeverBlue's Answer to the Complaint is currently due on or about May 4, 2010. NeverBlue has obtained the consent of Plaintiffs' counsel to file its Answer by May 24, 2010. The Complaint is 75 pages and alleges violations of various federal statutes by several defendants from numerous jurisdictions. Due to these and other factors, NeverBlue needs additional time to adequately respond to the Complaint. NeverBlue therefore requests that it be allowed to answer the Complaint by May 24, 2010. A proposed Order has been filed with this motion. DATED May 4, 2010. HOLLAND & HART LLP /s/ Romaine C. Marshall Romaine C. Marshall Approved as to form: FABIAN & CLENDENIN /s/ Philip D. Dracht Attorneys for Plaintiffs 4804586_1.DOC 2

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