Google v. Pacific Webworks

Filing 80

MOTION for Extension of Time to File Response/Reply as to 73 MOTION to Dismiss Bloosky's Third-Party Complaint filed by ThirdParty Plaintiff Bloosky Interactive, LLC, Defendant Bloosky Interactive, LLC. (Attachments: # 1 Text of Proposed Order)(Clark, Bryan)

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Google v. Pacific Webworks Doc. 80 LATHROP & GAGE LLP Blaine C. Kimrey (Pro Hac Vice) Bryan K. Clark (Pro Hac Vice) 100 N. Riverside Plaza, Suite 2100 Chicago, IL 60606 Telephone: (312) 920-3300 Facsimile: (312) 920-3301 CHRISTIANSEN & JACKSON PC Blair R. Jackson (10170) Greg Christiansen (10755) 10421 S. Jordan Gateway, Suite 600 South Jordan, UT 84095 Telephone: (801) 576-2662 Attorneys for defendant Bloosky Interactive, LLC IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH, CENTRAL DIVISION GOOGLE, INC., a Delaware corporation, Plaintiff, v. BLOOSKY INTERACTIVE, LLC, a Nevada limited liability company, and DOES 2-50, Defendant. UNOPPOSED MOTION FOR EXTENSION Case No. 09-cv-1068-BSJ District Judge Bruce S. Jenkins Defendant/third-party plaintiff Bloosky Interactive, LLC ("Bloosky"), by and through its counsel, Lathrop & Gage LLP, respectfully moves pursuant to Fed. R. Civ. P. 6(b) and D.U. Civ. R. 77-2(a)(2) for an extension of time to respond to third-party defendant Pacific WebWorks, Inc.'s ("PWW") Motion to Dismiss Bloosky's Third-Party Complaint. In support of this motion, Bloosky states as follows: 1 1. PWW filed a Motion to Dismiss Bloosky's Third-Party Complaint under Fed. R. Civ. P. 12(b) on September 1, 2010. Pursuant to D.U. Civ. R. 7-1(b)(4) and Fed. R. Civ. P. 6, Bloosky's response is therefore due September 29, 2010. 2. Bloosky's attorneys need additional time to analyze and respond to PWW's motion. Bloosky therefore requests a 14-day extension of time, up to and including October 13, 2010, to file its response. 3. The time for Bloosky to respond has not yet expired, and this motion is not being made for purposes of delay or any other vexatious purposes. 4. Counsel for Bloosky has contacted counsel for PWW, and they have no objection to the proposed 14-day extension. WHEREFORE, Bloosky respectfully requests that this Court grant its Motion for Extension, granting Bloosky an additional 14 days to respond to PWW's Motion to Dismiss Bloosky's Third-Party Complaint. Dated: September 24, 2010 Respectfully submitted, /s/ Bryan K. Clark LATHROP & GAGE LLP Blaine C. Kimrey (Pro Hac Vice) Bryan K. Clark (Pro Hac Vice) CHRISTIANSEN & JACKSON PC Greg Christiansen, #10755 Blair Jackson, #10170 Attorneys for defendant-third party plaintiff Bloosky Interactive, LLC 2 CERTIFICATE OF SERVICE I, Bryan K. Clark, hereby certify that on this 24th day of September, 2010, a true and correct copy of the foregoing was served by CM/ECF to the parties registered with the Court's CM/ECF system. /s/ Bryan K. Clark 3

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