Free Notice (Other) - District Court of California - California

Case 3:07-cv-02156-L-AJB

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Filed 12/06/2007

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Terrence P. McMahon (State Bar No. 71910) Stephen J. Akerley (State Bar No. 160757) James W. Soong (State Bar No. 196092) McDERMOTT WILL & EMERY LLP 3150 Porter Drive Palo Alto, CA 94304 Telephone: 650.813.5000 Facsimile: 650.813.5100 Attorneys for Defendant TZERO TECHNOLOGIES, INCORPORATED

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA PULSE~LINK INCORPORATED,

LLP

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ATTORNEYS AT LAW

M C D ERMOTT W ILL & E MERY

Civil No. 07cv2156-L(AJB) Electronic Case Filing RENEWED JOINT MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

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v. 13 14 15 16 17 18 19 20 21 22 23 24 TZERO TECHNOLOGIES, INCORPORATED, Defendant.

On December 3, 2007, Plaintiff Pulse~Link Incorporated ("Pulse~Link") and Defendant Tzero Technologies, Incorporated ("Tzero") jointly moved for an Order extending the time for Defendant Tzero to respond to Plaintiff Pulse~Link's Complaint to January 2, 2008. On December 4, 2007, the Court denied the motion without prejudice, and noted that the Court's docket did not include an application for substitution of counsel in this action. Plaintiff Pulse~Link and Defendant Tzero now hereby renew their joint motion for an extension of time to respond to the Plaintiff Pulse~Link's Complaint to January 2, 2008.

25 26 27 28 Defendant Tzero recently retained the undersigned as new counsel to replace its former counsel in the instant action, as well as Civil No. 07cv1125-L(AJB). No formal application for substitution of counsel was submitted in the instant action because, according to the Court's docket, former
Renewed Motion for Extension of Time to Respond to Complaint 07 CV 2156 L (AJB)

Case 3:07-cv-02156-L-AJB

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Filed 12/06/2007

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counsel for Defendant Tzero never made an appearance herein. In contrast, a Substitution of Attorneys was filed on December 3, 2007 in Civil No. 07cv1125-L(AJB) because former counsel for Defendant Tzero, in fact, did make an appearance therein. In view of the recent retention of new counsel by Defendant Tzero, the parties believe that an extension would allow sufficient time

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M C D ERMOTT W ILL & E MERY LLP

for Defendant Tzero to properly respond to the Complaint in the instant action. This extension is not sought for improper delay and no other deadlines will be affected.

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ATTORNEYS AT LAW

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Renewed Motion for Extension of Time to Respond to Complaint

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07 CV 2156 L (AJB)

Case 3:07-cv-02156-L-AJB

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Filed 12/06/2007

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M C D ERMOTT W ILL & E MERY LLP

STIPULATED AND AGREED TO: Dated: December 5, 2007 McDermott Will & Emery LLP certifies that it has authorization for the electronic signatures of the individuals identified in this document. McDERMOTT WILL & EMERY LLP By: s/James W. Soong Terrence P. McMahon Stephen J. Akerley James W. Soong Attorneys for Defendant TZERO TECHNOLOGIES, INCORPORATED

Dated: December 5, 2007

HELLER EHRMAN LLP By: s/Matthew C. Lapple John M. Benassi Matthew C. Lapple Samuel R. Hellfeld Attorneys for Plaintiff PULSE~LINK INCORPORATED

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ATTORNEYS AT LAW

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MPK 136018-1.081550.0011

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Renewed Motion for Extension of Time to Respond to Complaint

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07 CV 2156 L (AJB)