Free Motion for Extension of Time to File Answer - District Court of Delaware - Delaware

Case 1:07-cv—00371-l\/IPT Document 7 Filed 06/19/2007 Paget of2
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
SECURITY NETWORKS, LLC, :
Plaintiff, Civil No. 1:07-cv-00371
vs.
ALARM ONE, INC. and PETER MALTBY,
Defendants.
MOTION OF DEFENDANT PETER MALTBY FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S VERIFIED COMPLAINT
Defendant Peter Maltby ("Maltby") by and through its undersigned counsel,
hereby moves the Court for an extension of time to file his response to the Verified
Complaint filed by Security Networks, LLC ("Plaintift”'). Maltby respectfully requests
that he be granted an extension until June 29, 2007 to respond to the Verified
Complaint. Additional time is necessary to allow Maltby to engage local counsel and to
prepare properly l\/|a|tby’s response to the Verified Complaint. Plaintiff will not be
prejudiced by a modest extension because the Verified Complaint has only recently
been filed.
Counsel for Maltby left a detailed voicemail for Plaintiff's counsel on Friday, June
15, 2007 explaining that Maltby was engaging Delaware counsel to assist him in the
-Iii/oé:;nln;ent#: 62410

Case 1:07-cv—00371-MPT Document 7 Filed 06/19/2007 Page 2 of 2
above-captioned lawsuit, and that Maltby likely would need an extension of time to
respond to the Verified Complaint. Plaintiff’s counsel has not responded to this
voicemail. On Tuesday, June 19, 2007, MaItby's Delaware counsel was informed,
through Plaintiffs counseI's assistant, that Plaintiff would not grant Maltby any
extension of time to respond to the Verified Complaint.
As such, Maltby respectfully requests that the Court extend his time to respond
to the Verified Complaint to and including June 29, 2007. Maltby has submitted a
proposed Order granting such request for the Court’s convenience.
DATED this 19th day of June, 2007.
e . -’•MOf`I3CO,P I
{Af · /
F n is A. Monaco, .(#2 8)
201 N. Orange Street, Suite 400
Wilmington, DE 19801
(302) 656-8162
and
Jerome Romero (Utah Bar #5139)
Troy J. Aramburu (Utah Bar #10444)
JONES WALDO HOLBROOK & McDONOUGH PC
170 South Main Street, Suite 1500
Salt Lake City, Utah 84101
77429lvl 2

Case 1:07-cv—00371-I\/IPT Document 7-2 Filed 06/19/2007 Page 1 of 1
CERTIFICATE OF SERVICE
I, Kristie L. Dalton, certify that I am not less than 18 years of age, and that I caused
service of the foregoing document to be made via electronic notice and facsimile on June 19,
2007 upon:
David E. Wilks, Esq.
Reed Smith, LLP
1201 Market Street, Suite 1500
Wilmington, DE 19801
Via Facsimile: 302-428-3996
Michael R. Lastowski, Esq.
Duane Morris, LLP
1100 North Market Street, Suite 1200
Wilmington, DE 19801
Via Facsimile: 302-657-4901
Edward J. Naughton, Esq.
Geraldine Aine, Esq.
Holland & Knight, LLP
10 St. James Avenue
Boston, MA 02116
Via Facsimile: 617-523-6850
Under penalty of perjury, I reclare that the foreg `ng is true and correct.
Dated: June 19, 2007 ¤\ isticy . Dalton,
Document #; 62411

Case 1:07-cv—00371-l\/IPT Document 7-3 Filed 06/19/2007 Page 1 of 1
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
SECURITY NETWORKS, LLC, :
Plaintiff, Civil No. 1:07-cv-00371
vs.
ALARM ONE, INC. and PETER MALTBY,
Defendants.
ORDER GRANTING MOTION OF DEFENDANT PETER MALTBY FOR EXTENSION
OF TIME TO RESPOND TO PLAlNTIFF’S VERIFIED COMPLAINT
Having reviewed Defendant Peter lVla|tby’s ("Maltby") Motion for Extension of
Time to Respond to Plaintiffs Verified Complaint, and for good cause appearing, IT IS
HEREBY ORDERED that Maltby shall have until June 29, 2007 to file a response to
Plaintiffs Verified Complaint.
DATED this day of 2007.
District Court Judge
Document#; 62409