Google v. Pacific Webworks

Filing 54

Second MOTION for Extension of Time to File Answer filed by Defendant Bloosky Interactive, LLC. (Attachments: # 1 Text of Proposed Order)(Jackson, Blair)

Blair R. Jackson (10170) CHRISTIANSEN & JACKSON, P.C. 10421 S. Jordan Gateway, Suite 600 South Jordan, Utah 84095 Telephone [phone] Facsimile 801.415.9340 Attorneys for Defendant Bloosky Interactive, LLC

UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION

GOOGLE, INC., a Delaware corporation,

DEFENDANT BLOOSKY INTERACTIVE, LLC'S SECOND Plaintiff, UNOPPOSED MOTION FOR v. EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PACIFIC WEBWORKS, INC., a Nevada PLAINTIFF'S FIRST AMENDED corporation, BLOOSKY INTERACTIVE, COMPLAINT LLC, a Nevada limited liability company, and DOES 2-50, CASE NO. 2:09-CV-1068-BSJ Defendants. Judge: Bruce S. Jenkins Defendant, BLOOSKY INTERACTIVE, LLC (herein "Bloosky"), by and through its undersigned counsel, files this Unopposed Motion for Extension of Time to Answer, Move or Otherwise Respond to the First Amended Complaint filed by Plaintiff, GOOGLE, INC. (herein "Google"). Google filed its original complaint on December 7, 2009, against Defendant, PACIFIC WEBWORKS, INC. (herein "Pacweb"). Google filed its First Amended Complaint, adding Bloosky as a defendant, on May 18, 2010. Bloosky's answer was initially due on June 11, 2010.

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DEFENDANT BLOOSKY INTERACTIVE, LLC'S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT

On June 11, 2010, Bloosky brought an Unopposed Motion for Extension of Time to Answer, Move or Otherwise Respond to the First Amended Complaint filed by Google. On June 14, 2010, this Court granted Bloosky's unopposed motion, and ordered Bloosky to answer, move or otherwise respond to Google's First Amended Complaint on or before June 25, 2010. Bloosky has been actively negotiating with Google in an attempt to settle the instant matter without the necessity of further litigation. Additionally, Bloosky is currently seeking outside counsel to represent it for the pendency of this matter. In the interest of judicial economy, Bloosky respectfully moves the Court for an extension of time to answer, move or otherwise respond to Google's First Amended Complaint. Specifically, Bloosky requests that it be permitted to answer, move or otherwise respond to Google's First Amended Complaint no later than Friday, July 2, 2010. Google does not oppose this request. WHEREFORE, Bloosky respectfully requests that the Court grant this Unopposed Motion for Extension of Time to Answer, Move or Otherwise Respond to the First Amended Complaint, up to and including Friday, July 2, 2010. A proposed Order granting this unopposed motion is being submitted concurrently. RESPECTFULLY SUBMITTED. DATED: June 25, 2010 CHRISTIANSEN & JACKSON, PC

By /s Blair R. Jackson /s _ Blair R. Jackson Attorneys for Defendant, Bloosky Interactive, LLC

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DEFENDANT BLOOSKY INTERACTIVE, LLC'S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT

CERTIFICATE OF CONFERENCE Counsel for Defendant, Bloosky Interactive, LLC, conferred with counsel for Plaintiff, Google, Inc., concerning the relief requested in this motion on June 25, 2010. Counsel for Google, Inc. stated that they had no objection to the relief requested herein.

CERTIFICATE OF SERVICE I hereby certify that on June 25, 2010, I electronically submitted the foregoing document with the clerk of the court for the U.S. District Court, Central Division of Utah, using the electronic case files system of the court. The electronic case files system sent a "Notice of Electronic Filing" to individuals who have consented in writing to accept this Notice as service of this document by electronic means. ____________________________________ DATED: June 25, 2010 CHRISTIANSEN & JACKSON, PC

By /s Blair R. Jackson /s _ Blair R. Jackson Attorneys for Defendant, Bloosky Interactive, LLC

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DEFENDANT BLOOSKY INTERACTIVE, LLC'S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT