Zapmedia Services, Inc. v. Apple, Inc. Doc.

10
Case 2:08-cv-00104-DF-CE Document 10 Filed 03/26/2008 Page 1 of 2

IN THE UNITED STATES COURT

FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

ZAPMEDIA SERVICES, INC., §

a foreign corporation, §
§
Plaintiff, §
§
v. § CIVIL ACTION NO. 2:08-CV-104
§
APPLE INC., § JURY TRIAL REQUESTED
a foreign corporation §
§
§
Defendant. §

UNOPPOSED MOTION EXTENDING THE TIME FOR DEFENDANT APPLE INC. TO

RESPOND TO ZAPMEDIA SERVICES, INC.’S ORIGINAL COMPLAINT

Defendant Apple Inc. (“Apple”) respectfully requests that the Court enlarge the time

within which Apple is required to move, answer, or otherwise respond to ZapMedia Services,

Inc.’s Complaint up to and including Friday, May 2, 2008. Apple was served on March 14,

2008. Its deadline to answer was originally April 3, 2008. The parties have agreed to an

extension of an additional 29 days, so that the new deadline falls on Friday, May 2, 2008. Apple

seeks this extension of time not for delay but for good cause and so that justice may be served.

ZapMedia Services, Inc. is not opposed to this motion. A proposed order granting

Apple’s requested relief is attached.

Respectfully Submitted,

March 26, 2008 /s/ Lou Brucculeri

Lou Brucculeri
Texas Bar No. 00783737
Russell Wong
Texas Bar No. 21884235
Keana T. Taylor
Texas Bar No. 24042013
WONG, CABELLO, LUTSCH,

Dockets.Justia.com
 Case 2:08-cv-00104-DF-CE Document 10 Filed 03/26/2008 Page 2 of 2

RUTHERFORD & BRUCCULERI, L.L.P.

20333 SH 249, Suite 600
Houston, TX 77070
832-446-2400 – Phone
832-446-2424 – Fax
Email: lbrucculeri@counselip.com
Email: rwong@counselip.com
Email: ktaylor@counselip.com
ATTORNEY FOR DEFENDANT
APPLE INC.

CERTIFICATE OF SERVICE

I hereby certify that counsel of record who are deemed to have consented to
electronic service are being served today, March 26, 2008 with a copy of Unopposed Motion
Extending the Time for Defendant Apple Inc. to Respond to ZapMedia Services, Inc.’s
Original Complaint via the Court’s CM/ECF system per Local Rule CV-5(a)(3). Any other
counsel of record will be served by electronic mail, facsimile transmission and/or first class mail
on this same date.

/s/ Keana T. Taylor

Keana T. Taylor