Opinion
Case No. 3:11-CV-04621 (EDL)
11-22-2011
BRADFORD TECHNOLOGIES, INC., Plaintiff, v. NCV SOFTWARE.com, an entity of unknown form; METRO NATIONAL FINANCIAL, LLC, a Utah limited liability company, KARMA TECHNOLOGIES, LLC, a Utah limited liability company, JOHN DAVID BIGGERS, an individual, RODNEY NEWMAN, an individual, RICHARD PETER STEVES, an individual, RICHARD FRANK, an individual, and DOES 1-50, Defendants.
GREENBERG TRAURIG, LLP By: Matthew L. Reagan - and - ANDERSON & KARRENBERG Thomas R. Karrenberg Heather M. Sneddon Samantha J. Slark Attorneys for Defendant KARMA TECHNOLOGIES, LLC Stipulated: THE HERITAGE LAW GROUP, P.C. By: Roger D. Wintle Attorneys for Plaintiff BRADFORD TECHNOLOGIES, INC.
GREENBERG TRAURIG, LLP
Kurt A. Kappes, CA Bar No. 146384
Matthew L. Reagan, CA Bar No. 261832
ANDERSON&KARRENBERG
Thomas R. Karrenberg (admitted pro hac vice)
Heather M. Sneddon (admitted pro hac vice)
Samantha J. Slark (admitted pro hac vice)
Attorneys for Defendant
KARMA TECHNOLOGIES, LLC
[PROPOSED] ORDER GRANTING STIPULATED REQUEST FOR
EXTENSION OF TIME FOR KARMA TECHNOLOGIES, LLC TO FILE A
REPLY IN SUPPORT OF ITS MOTION TO DISMISS OR, IN THE
ALTERNATIVE, FOR MORE DEFINITE STATEMENT
Judge: Magistrate Judge Elizabeth D. Laporte
Defendant Karma Technologies, LLC ("Karma"), by and through its undersigned counsel, hereby requests an extension of time to file a reply memorandum in support of its Motion to Dismiss or, in the Alternative, for More Definite Statement (the "Motion to Dismiss"). The reply is currently due on Wednesday, November 23, 2011 (the day before Thanksgiving), and Karma requests an extension until November 30, 2011.
As set forth in the Declaration of Heather M. Sneddon, filed concurrently herewith, Karma requests the foregoing extension in light of the Thanksgiving holiday and the previously-scheduled family vacations of its attorneys. Karma has not previously requested an extension of time by stipulation or through Court order. In addition, because the hearing on Karma's Motion to Dismiss is not scheduled until December 13, 2011, the filing of Karma's reply memorandum by November 30, 2011 should not affect the schedule in this case. Finally, Plaintiff Bradford Technologies, LLC, through its undersigned counsel, stipulates to Karma's requested extension.
Accordingly, Karma respectfully requests that it be granted an extension until November 30, 2011 to file a reply memorandum in support of its Motion to Dismiss.
Respectfully submitted,
GREENBERG TRAURIG, LLP
By: Matthew L. Reagan
- and
ANDERSON & KARRENBERG
Thomas R. Karrenberg
Heather M. Sneddon
Samantha J. Slark
Attorneys for Defendant
KARMA TECHNOLOGIES, LLC
Stipulated:
THE HERITAGE LAW GROUP, P.C.
By: Roger D. Wintle
Attorneys for Plaintiff
BRADFORD TECHNOLOGIES, INC.
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
BY THE COURT:
The Honorable Elizabeth D. Laporte
U.S. District Court Magistrate Judge