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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`B.E. TECHNOLOGY, L.L.C.,
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`Case No. 2:12-cv-02783-JPM-cgc
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`v.
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`TWITTER, INC.,
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`Plaintiff,
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`Defendant.
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`CONSENT MOTION FOR AN EXTENSION OF TIME,
`MEMORANDUM,
`AND LR 7.2 CERTIFICATION OF CONSULTATION
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`Pursuant to Fed. R. Civ. P. 6(b)(1)(A) of the Federal Rules of Civil Procedure, Defendant
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`Twitter, Inc. (“Twitter”) hereby moves that:
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`(1)
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`Twitter’s deadline under Fed. R. Civ. P. 12(a) to respond to the Complaint be
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`extended and set as December 31, 2012; and
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`(2)
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`for clarity, the deadline for Plaintiff’s Initial Infringement Contentions be set as
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`January 7, 2013.
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`As noted in the certification below, Plaintiff has consented to the requested relief.
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`MEMORANDUM
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`Twitter was served with the Summons and Complaint in this matter on or about October
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`9, 2012. This is a patent infringement case, and Twitter respectfully requests additional time to
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`consult with lead counsel, consider and evaluate the Complaint, and prepare a responsive
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`pleading. Given the approaching holidays, counsel for Plaintiff has kindly consented to an
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`1
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`Case 2:12-cv-02783-JPM-cgc Document 14 Filed 10/26/12 Page 2 of 3 PageID 52
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`extension through December 31, 2012. Should the Court grant the requested extension, Twitter,
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`in consultation with counsel for Plaintiff, also requests that the deadline for service of Plaintiff’s
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`Initial Infringement Contentions be set as January 7, 2013.
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`CERTIFICATION OF CONSULTATION
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`Pursuant to LR 7.2(a)(1)(B), the undersigned certifies that after consultation between
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`counsel for the parties, all parties are in agreement with the action requested in the above motion.
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` s/ Jonathan D. Rose
`Jonathan D. Rose
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`Respectfully submitted,
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` s/ Jonathan D. Rose
`Jonathan D. Rose (No. 20967)
`BRADLEY ARANT BOULT CUMMINGS LLP
`1600 Division Street, Suite 700
`Nashville, Tennessee 37203
`Telephone: (615) 252-2308
`Facsimile: (615) 252-6308
`E-Mail: jrose@babc.com
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`Attorneys for Defendant
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`Case 2:12-cv-02783-JPM-cgc Document 14 Filed 10/26/12 Page 3 of 3 PageID 53
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`CERIFICATE OF SERVICE
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`I hereby certify that on October 26, 2012, the foregoing is being served the foregoing via
`the Court’s Electronic Filing System, upon the following:
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`Craig Robert Kaufman
`Robert Edward Freitas
`Hsiang Hong Lin
`Qudas B. Olaniran
`FREITAS TSENG & KAUFMAN, LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
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`Richard M. Carter
`Adam Calhoun Simpson
`MARTIN TATE MORROW & MARSTON
`International Place, Tower II
`6410 Poplar Ave., Ste. 1000
`Memphis, TN 38119
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` /s/ Jonathan D. Rose
`Jonathan D. Rose
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`3
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