Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA596905
`ESTTA Tracking number:
`04/07/2014
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91214205
`Plaintiff
`Crambo, S.A.
`Stewart J. Bellus
`COLLARD AND ROE
`1077 NORTHERN BLVD
`ROSLYN, NY 11576
`UNITED STATES
`sbellus@collardroe.com
`Other Motions/Papers
`Stewart J Bellus
`sbellus@collardroe.com
`/sjb/
`04/07/2014
`Opposer's Motion to Extend Time To Respond to Discovery.pdf(969639 bytes )
`
`Proceeding
`Party
`
`Correspondence
`Address
`
`Submission
`Filer's Name
`Filer's e-mail
`Signature
`Date
`Attachments
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`.....................................................................--X
`
`Opposition No.
`91214205
`
`) J
`
`) ) )
`
`)
`
`) )
`
`) )
`
`) )
`
`CRAMBO, S.A.
`
`Opposer,
`
`V.
`
`PANASONIC CORPORATION
`
`Applicant.
`
`..................................................................... --X
`
`0PPOSER”S MOTION FOR 30-DAY EXTENSION OF TIME TO RESPOND TO
`
`APPLICANT’S DISCOVERY REQUESTS
`
`Opposer hereby requests tl1at this Board issue an order extending the time by which it
`must respond to Applicant’s Discovery by 30 Days. Opposer states the following in support of its
`Motion:
`
`1.
`
`On March 24, 2014, counsel for Applicant served the following Discovery
`Requests on Opposer by mail:
`
`A.
`
`B.
`
`C.
`
`APPLICANT AND COUNTERCLAIM DEFENDANT’S FIRST SET OF
`INTERROGATORIES TO OPPOSER
`
`APPLICANT AND COUNTERCLAIM’S FIRST REQUESTS FOR
`PRODUCTION OF DOCUMENTS AND THINGS
`
`APPLICANT AND COUNTERCLAIM PLAlNTIFF’S FIRST REQUEST
`FOR ADMISSIONS.
`
`See all three sets of Discovery attached to this Motion for Extension of Time.
`
`Although the certificate of service was dated March 24, 2014, Opposer did not
`receive these requests until March 28, 2014. See attached cover letter from
`Applicant’s counsel, Harness Dickey addressed to undersigned counsel.
`
`Applicant’s Interrogatories are fourteen (14) pages long, and include thirty (30)
`numbered Interro gatories with many of the interrogatories containing multiple
`sub-parts.
`
`Applicant’s Requests For Production Of Documents is eight (8) pages long and
`contains fifty (50) paragraphs of requests.
`
`2.
`
`3.
`
`4.
`
`

`
`5.
`
`6.
`
`7.
`
`8..
`
`9.
`
`Applicant’s Request For Admissions is eight (8) pages long and contains one
`hundred thirteen (113) paragraphs of Requests.
`
`Under any circumstances, responding to all this discovery within the 30-day limit
`provided by the Rules would it be daunting. However, Opposer’s situation is even
`more difficult because undersigned counsel works in the typical way through a
`foreign (Spanish) associate. Moreover, Opposer itself is located in Spain. Neither
`associate nor client is familiar with US. opposition practice, so this extra step in
`consultation between U.S. counsel and client is more difficult than usual.
`Moreover, there is a language barrier, as Opposer is not completely fluent in
`English. This combination of lengthy discovery requests, the need to work with a
`foreign associate and foreign client unfamiliar with US practice, and the language
`barrier, would make it nearly impossible for any party to respond to the volume of
`discovery served by Applicant within thirty days.
`
`Equally important is that Applicant would suffer absolutely no prejudice if this
`response period is extended. Discovery opened on March 6, 2014, and does not
`close until September 2, 2014, almost five months from now. No previous
`extensions have been sought or obtained. This slight delay will not have any
`negative impact on Applicant.
`
`Pursuant to Rules of Practice, undersigned counsel made a good-faith effort to
`resolve this issue by communicating with Applicant’s counsel several times to
`seek consent for a 30-day extension of time. Applicant’s counsel clearly indicated
`that Applicant would not consent to any extension. As the parties were otherwise
`unable to resolve their different positions, this Motion is necessary.
`
`The Certificate of Service on Applicant’s Discovery was March 24, 2014. Adding
`three days for mailing, the deadline for Opposer’s Responses would be April 27,
`2014. Opposer now is requesting a 30-day extension until May 27, 2014.
`
`Based on the above, Opposer respectfully requests that this Board grant a 30-Day
`Extension of Time, with the new deadline being May 27, 2014
`
`Crambo, S.A.
`
`
`
`Sara M. Dorchak
`
`COLLARD & ROE, P.C.
`1077 Northern Boulevard
`
`Roslyn, New York 11576
`Telephone: (516) 365-9802
`E—mail: sbellus@collardroe.com
`sdorchakgagcollardroecom
`
`Attorneys for Opposer
`CRAMBO, S.A.
`
`Dated: April 7, 2014
`
`

`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the forgoing
`“OPPOSER”S MOTION FOR 30-DAY EXTENSION OF TIME TO RESPOND TO
`APPLICANT’S DISCOVERY REQUESTS” has this 7th day of April 2014 been sent by prepaid
`First Class Mail to:
`
`Gregory A. Stobbs
`Geoffrey D. Aurini
`Harness, Dickey & Pierce, P.L.C.
`5445 Corporate Dr Ste 200
`Troy, Michigan 48098-2683
`
`
`
`T:\users\sbel]us\ECONAV\ECONAV - Motion for Extension of '['ime.wpd