Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1:08-cv-00062-GMS

Document 32

Filed 05/13/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

LIVEPERSON, INC., Plaintiff, v. NEXTCARD, LLC and MARSHALL CREDIT STRATEGIES, LLC, Defendants.

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C.A. 08-62 GMS

JURY TRIAL

STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR DEFENDANTS TO FILE THEIR REPLY BRIEF IN SUPPORT OF THEIR MOTION TO DISMISS WHEREAS, on April 7, 2008, defendant NextCard, LLC and Marshall Credit Strategies, LLC (collectively "Defendants") filed Motions to Dismiss for Failure to State a Claim and for Lack of Personal and Subject Matter Jurisdiction and an opening brief in support thereof (D.I. 22, 23); and WHEREAS, on May 8, 2008, plaintiff LivePerson, Inc. ("Plaintiff') filed an Answering Brief in opposition to Defendants' motions, and also filed a Motion for Leave to File a Second Amended Complaint and a Motion for Targeted Jurisdiction Discovery; and WHEREAS, Defendants' Reply Brief in support of their Motions to Dismiss are due by April 15, and Defendants' Answering Brief in opposition to Plaintiff's motions are due by May 22; and WHEREAS, counsel for Defendants is currently traveling and so requires a brief extension to be able to finish the briefing.

Case 1:08-cv-00062-GMS

Document 32

Filed 05/13/2008

Page 2 of 2

NOW, THEREFORE, it is hereby stipulated by and between the parties hereto, through their respective counsel, and subject to the approval of the Court, that the time by which Defendants must file their Reply Brief in support of their Motions to Dismiss is extended to May 22, 2008.

/s/ David L. Finger___________________ /s/ Andrew A. Lundgren____________ Melanie K. Sharp (DE Bar ID # 2501) David L. Finger (DE Bar ID #2556) Andrew A. Lundgren (No. 4429) Finger & Slanina, LLC Young Conaway Stargatt & Taylor LLP One Commerce Center The Brandywine Building 1201 Orange Street, Suite 725 th 1000 West Street, 17 Floor Wilmington, DE 19801-1155 Wilmington, Delaware 19801 (302) 994-6766 (302) 571-6681 Counsel for Plaintiff Counsel for Defendants

SO ORDERED this ______ day of May, 2008.

_______________________________________ Sleet, J.