`
`1,
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`the Matter of Trademark Application
`In
`Serial No. 75/789,080
`
`RMV CELLARS, LLC
`Opposer,
`
`as »....:),1;,ff,;2T3‘;:”W
`
`t m
`
`-V-
`
`Opposition No. 91151893
`
`CALONA WINES LTD
`
`Applicant.
`
`THIRD CONSENTED TO MOTION FOR EXTENSION OF DEADLINES
`
`Opposer, RMV Cellars, LLC, respectfully moves for an extension of the testimony
`
`deadlines for 90 days, beyond the last request for extension as follows:
`
`30-day testimony period for party in
`position of plaintiff to close
`
`30-day testimony period for party in
`position of defendant to close
`
`April 26, 2004
`
`June 23,2004
`
`15-day rebuttal period for party in the
`position of plaintiff to close
`
`July 8, 2004
`
`The requested extension is not for the purposes of mere delay. Opposer has
`
`submitted a motion for leave to amend the notice of opposition and to reopen discovery
`
`on limited issues. The parties wish to conserve resources and await the taking 0
`
`testimony until the parties learn of the Board’s decision on that motion. This is the
`
`second such motion under
`
`these circumstances.
`
`Chuck McClung, counsel
`
`for
`
`Applicant, has consented to this motion and the requested extension in a telephone
`
`conversation on December 22, 2003.
`
`THIRD CONSENTED TO MOTION FOR EXTENSION
`OF DEADLINES --1
`
`KURT M. RYLANDER TRIAL AND
`PATENT ATTORNEY AT LAW PC
`1014 FRANKLIN smear, sums 206
`VANCOUVER, WA 98660
`360.750.9931
`
`
`
`
`
`is
`
`WHEREFORE, the Board should grant Opposer’s consented to motion.
`
`DATED THIS January 22, 2004
`
`
`
`Respectfully submitted,
`
`KURT M.
`
`AT LAW PC
`
`
`
`
`
`ER, Reg. No. 43,897
`URT M. RYLA
`1014 Franklin Stree ,
`uite 206
`
`Vancouver, WA 98660
`
`
`
`(360) 750-9931
`Attorney for Opposer
`
`
`
`CERTIFICATE OF SERVICE TO APPLICANT
`
`inserted an envelope
`I HEREBY CERTIFY that on the date signed below I
`
`
`containing the document to which this certificate is attached into the U.S. Mfirst
`class, postage pre-paid, addressed to the attorney of record f - - uck
`
`
`‘
`
`1600 ODS
`
`
`
`'
`
`
`
`
`KURT . RYLANDER
`
`I hereby certify that on the date signed below the
`original and two copies of the document to which this
`
` DATED January 22, 2004
`
` Certificate of Mailing
`
`
`certification is attached is being deposited with the
`Commissi
`
`- Board,
`
`
`2 202-3513.
`Date:Janua
`
`or Trad n-.-
`_!.=iI
`'- .
`
`r
`.
`
`,
`
`‘
`
`I 've, Arlington, VA
`
`
`
`" M. RYLANDER
`
`THIRD CONSENTED TO MOTION FOR EXTENSION
`OF DEADLINES --2
`
`KURT M. RYLANDER TRIAL AND
`PATENT ATTORNEY AT LAW PC
`1014 FRANKLIN STREET. SUITE 206
`VANCOUVER, WA 98660
`360.750.9931
`
`
`
`
`
`KURT M. RYLANDER
`
`TRIAL & PATENT ATTORNEY AT LAW PC
`
`January 22, 2004
`
`File no. RMV03
`
`BOX TTAB NO FEE
`Assistant Commissioner for Trademarks
`
`Trademark Trial and Appeal Board
`2900 Crystal Drive
`Arlington, VA 22202-3513
`
`RE:
`
`SANDHILL OPPOSITION
`
`Dear Sir or Madam:
`
`Enclosed for filing please find an original Third Consented to Motion for
`Extension of Deadlines. Also enclosed herein please find a postage-prepaid postcard
`for date stamping and return to this office. Please let me know if there i
`ything I
`
`can do for you. KURT M. RYLANDER
`
`
`
`KMR;wf
`Cc‘
`Client
`
`Chuck McClung
`
`Main Office
`l0l4 Franklin Street
`Suite 206
`Vancouver, Washington
`98660
`Tel: 360.750.9931
`Fax: 360.397.0473
`www.rylanderlaw.com
`
`Practice Areas
`Patents, Trademarks, Copyrights
`Infringement & Unfair Competition
`Government Contract Claims
`Federal Tort Claims
`Commercial Litigation
`Personal Injury
`Criminal Defense
`Federal Regulatory Disputes
`Trials and Appeals
`
`Licensed
`State of Washington
`State of Oregon
`District of Columbia
`U.S. Patent & Trademark Office
`Canadian Patent Office
`
`Member of Bar
`U.S. Supreme Court
`Federal Circuit
`D.C. Circuit
`Court of lntemational Trade
`Court of Federal Claims
`D.C. District Court
`Western District of Washington
`Eastern District of Washington
`Southern District of Maryland
`District of Oregon
`
`Associations
`Am. Intellectual Prop. Law Assn
`Wash. State Patent Law Assn
`Ore. Patent Law Assn
`Assn of Trial Lawyers of Am.
`Wash. State Trial Lawyer's Assn
`American Bar Assn
`Sec. Intellectual Property Law
`Sec. Public Contract Law
`Federal Circuit Bar Assn
`Oregon State Bar Assn
`Sec. Intellectual Property
`Sec. Litigation
`Sec. Business Litigation
`Multnomah Bar Assn
`Washington State Bar Assn
`Sec. Litigation
`Sec. Intellectual Property
`Clark County Bar Assn
`Clark Criminal Defense Bar
`District of Columbia Bar Assn
`Federal Board of Contract Appeals
`Bar Assn
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