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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
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`Civil Action No. 1:17-cv-02692
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`REALTIME ADAPTIVE STREAMING LLC,
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`v.
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`POLYCOM, INC.,
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`Plaintiff,
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`Defendant.
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`DEFENDANT POLYCOM’S UNOPPOSED MOTION
`FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND
`TO PLAINTIFF’S ORIGINAL COMPLAINT
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`Defendant Polycom, by and through undersigned counsel, requests the Court
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`grant a thirty day extension of time to answer and/or otherwise respond to Plaintiff’s
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`Original Complaint. This is Polycom’s first request for an extension.
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`Plaintiff’s Original Complaint was filed on November 10, 2017. Doc. 1. Polycom
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`was served on December 4, 2017. Doc. 14. Polycom’s answer or response is thus due
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`on December 26, 2017. Polycom requests the Court extend Polycom’s deadline to
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`answer or respond by thirty (30) days, until January 25, 2018. Plaintiff agrees to
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`Polycom’s request.
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`Polycom requests an extension of time to investigate the facts and allegations in
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`the Complaint, as well as to discuss the possibility of early settlement. Polycom also
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`requests this extension because its original deadline is the day after Christmas day, and
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`therefore key personnel necessary to assess and respond to the Complaint, at both
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`1
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`Case 1:17-cv-02692-RBJ Document 15 Filed 12/21/17 USDC Colorado Page 2 of 3
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`Polycom and its outside counsel, will be unavailable due to pre-planned holiday vacation
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`and travel.
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`Polycom does not seek this extension for any improper purpose, and no prejudice
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`will arise from the extension. No previous extensions of this deadline have been granted.
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`Pursuant to D.C.COLO.LCivR 6.1(c), undersigned counsel certifies that a copy of
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`this Motion will be served on undersigned’s client.
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`Wherefore, Polycom respectfully moves that the Court enter an order extending
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`the deadline to file an answer or otherwise respond to Plaintiff’s Original Complaint, for
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`thirty (30) days, through and including January 25, 2018.
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`DATED:
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`December 21, 2017
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`Respectfully submitted,
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`/s/ James H. Hall
`James H. Hall
`Blank Rome LLP
`717 Texas Avenue, Suite 1400
`Houston, Texas 77002
`Telephone: (713) 228-6601
`Fax: (713) 228-6605
`Email: JHall@BlankRome.com
`Attorney for Defendant Polycom, Inc.
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`Case 1:17-cv-02692-RBJ Document 15 Filed 12/21/17 USDC Colorado Page 3 of 3
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that Defendant’s counsel conferred with Plaintiff’s counsel
`regarding the relief requested in this motion via e-mail. Plaintiff’s counsel agreed to the
`requested relief and is unopposed to this motion.
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`/s/ James H. Hall
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`CERTIFICATE OF SERVICE
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`I hereby certify that on December 21, 2017, I electronically filed the foregoing with
`the Clerk of the Court by using the Court’s CM/ECF electronic filing system, which will
`send notification of such filing to the following e-mail addresses:
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`Brian David Ledahl
`Jay Young Chung
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`Marc Aaron Fenster
`Reza Mirzaie
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`Timothy T. Hsieh
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`Eric Bryan Fenster
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`(bledahl@raklaw.com)
`(jchung@raklaw.com)
`(mafenster@raklaw.com)
`(rmirzaie@raklaw.com)
`(thsieh@raklaw.com)
`(eric@fensterlaw.net)
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`/s/ Lynn Marlin
`Lynn Marlin
`Blank Rome LLP
`717 Texas Avenue, Suite 1400
`Houston, Texas 77002
`Telephone: (713) 228-6601
`Fax: (713) 228-6605
`Email: LMarlin@BlankRome.com
`Paralegal for Defendant Polycom, Inc.
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`3
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