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Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA659889
`ESTTA Tracking number:
`03/09/2015
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91206162
`Plaintiff
`Miss America Organization
`CHARLES N QUINN
`FOX ROTHSCHILD LLP
`747 CONSTITUTION DRIVE, SUITE 100
`EXTON, PA 19341
`UNITED STATES
`cquinn@foxrothschild.com, dmcgregor@foxrothschild.com,
`jdiguglielmo@foxrothschild.com, ipdocket@foxrothschild.com
`Other Motions/Papers
`CHARLES N. QUINN
`cquinn@frof.com, dmcgregor@frof.com, mscott@frof.com, cesch@frof.com
`/CHARLES N. QUINN/
`03/09/2015
`29237865_1_9 MARCH 2015 MAO SUBMISSION OF BODGE CONSENT TO
`SCHEDULE EXTENSION.PDF(117251 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`TRADEMARK TRIAL AND APPEAL BOARD
`
`Miss America Organization
`
`Opposer
`
`V.
`
`Jessica Lee Bodge
`
`Applicant
`
`2
`:
`.
`
`'
`
`Opposition 91206162
`Application 85/414,806
`Mark: LITTLE MISS OF AMERICA
`
`SUBMISSION OF CONSENT BY APPLICANT TO MOTION BY OPPOSER,
`
`THE MISS AMERICA ORGANIZATION, TO RESET DATES
`AND EXTEND COMMENCEMENT OF OPPOSER’S TESTIMONY PERIOD
`
`On 11 February 2015, the Miss America Organization (“Miss America”), the opposer in
`
`this trademark opposition proceeding, filed a motion with the Trademark Trial and Appeal Board
`
`to reset dates and thereby extend the date for commencement of Miss America’s testimony
`
`period by sixty days. At that time, Miss America’s testimony period was scheduled to open on
`
`27 February and to close thirty days later, on 28 March 2015.
`
`Accompanying that motion was a declaration of Miss America’s counsel noting that Miss
`
`America had tried, without success, to contact the applicant, Ms. Bodge, to solicit her consent to
`
`the motion. At that time, Ms. Bodge had not returned any of Miss America’s counsel’s e-mail
`
`messages or telephone calls. As a result, Miss America could not, when the motion was filed,
`
`represent that the motion had the consent of the applicant.
`
`Ms. Bodge, the applicant, has now replied to Miss America’s counsel and has consented
`
`to the requested extension of the Miss America’s testimony period. As evidence of this, there is
`
`attached to this paper an e-mail exchange ending on 6 March 2015 in which Ms. Bodge
`
`expresses her consent to the requested extension.
`
`29236536vl 03/09/2015 12:40 PM
`
`1
`
`000432.40l01/pleadings
`
`

`
`Miss America again respectfully request notification of grant of this motion, this time in
`
`View of the consent given by the applicant, Jessica Lee Bodge.
`
`Respectfully submitted,
`
`FOX ROTHSCHILD LLP
`
`/Charles N. Quinr1/
`Charles N. Quinn
`747 Constitution Drive, Suite 100
`
`Exton, PA 19341
`Tel: 610-458-4984
`
`Date:
`
`9 March 2015
`
`cquinn@foxrothschild.com
`Attorneys for Opposer, the Miss America Organization
`
`29236536v1 03/09/2015 12:40 PM
`
`2
`
`000432/10101/pleadings
`
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
`
`Miss America Organization
`
`Opposer
`
`V.
`
`Jessica Lee Bodge
`
`Applicant
`
`:
`:
`.
`
`.
`
`Opposition 91206162
`Application 85/414,806
`Mark: LITTLE MISS OF AMERICA
`
`CERTIFICATE OF SERVICE
`
`1, Charles N. Quinn, Esquire, hereby certify that, pursuant to the parties’ agreement for
`
`electronic service, a true and correct copy of the foregoing:
`
`SUBMISSION OF CONSENT BY APPLICANT TO MOTION BY OPPOSER,
`MISS AMERICA ORGANIZATION, TO RESET DATES
`'
`AND EXTEND COMMENCEMENT OF OPPOSER’S TESTIMONY PERIOD
`
`was served on Applicant as identified below, via electronic mail on 9 March 2015 at the email
`
`address below:
`
`Jessica Lee Bodge
`jessicabodge@msn.corn
`jessica@wa1ittlemissofamerica.com
`
`/Charles N. Quim1/
`Charles N. Quinn
`
`29236536v1 03/09/2015 12:40 PM
`
`3
`
`0O0432.40l0l/pleadings
`
`

`
`Quinn, Charles N.
`
`From:
`Sent:
`To:
`Subject:
`
`Jessica Bodge <jessicabodge@msn.com>
`Friday, March 06, 2015 1:26 AM
`Quinn, Charles N.
`Re: Miss America Organization v. Jessica Lee Bodge; Our File: OOO432.40lO1
`
`Yes this is fine my divorce mediation is this month so delaying this is fine with me. Please use the following
`email when contacting me please:
`Jessica@walittlemissofamerica.com please file necessary papers for an agreed order
`Thanks
`
`Jessica
`
`Sent from my iPhone
`
`> On Feb 9, 2015, at 9:40 AM, Quinn, Charles N. <CQuinn@foxrothschild.com> wrote:
`
`Dear Ms. Bodge,
`
`> >
`
`> >
`
`I have been extremely busy with some
`We are approaching the opening of plaintiff's testimony period.
`patent infringement litigation and have not had time to deal with this case.
`
`> >
`
`I am therefore asking you to consent to an extension of the plaintiff's testimony period. This will have no
`effect on your required dates, other than to push everything back on the calendar.
`
`> >
`
`We have granted you numerous extensions for several things in the past in this and the now closed case; I
`would appreciate your return courtesy in this situation.
`
`I will be happy to file the required papers; all ask is a return email from you consenting to this request.
`
`Regards,
`
`Charlie Quinn
`
`> >
`
`> >
`
`> >
`
`> > >
`
`Charles Quinn
`> Partner
`
`> Fox Rothschild LLP
`
`> Eagleview Corporate Center
`
`> 747 Constitution Drive, Suite 100, PO Box 673
`
`> Exton, PA 19341
`
`> (610) 458-4984 — direct
`
`> (610) 458—7337— fax
`> CQuinn@foxrothschild.com
`> www.foxrothschi|d.com
`
`—-—-—Original Message——-—-
`
`> >

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