Data Scape Limited v. Verizon Communications, Inc. et al

Western District of Texas, txwd-6:2019-cv-00312

Unopposed MOTION for Extension of Time to File Answer or Respond to Complaint by Verizon Connect, Inc.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, C.A. No. 6:19-cv-00312-ADA Plaintiff, v. JURY TRIAL DEMANDED VERIZON COMMUNICATIONS, INC., and VERIZON CONNECT, Defendants. UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO COMPLAINT Defendant Verizon Connect, by and through its undersigned counsel, hereby moves to extend its deadline to move, answer, or otherwise respond to the Complaint in this action from June 21, 2019 to July 21, 2019. This extension is necessary to allow Defendant sufficient time to finalize investigation of the allegations and respond to the allegations in the Complaint. Dated: June 14, 2019 Respectfully submitted, /s/ J. Mark Mann J. Mark Mann State Bar No. 12926150 mark@themannfirm.com G. Blake Thompson State Bar No. 24042033 blake@themannfirm.com MANN | TINDEL | THOMPSON 300 West Main St. Henderson, Texas 75652 Telephone: 903-657-8540 Facsimile: 903-657-6003 Attorneys for Defendant Verizon Connect 1 CERTIFICATE OF CONFERENCE I certify that on June 13, 2019, I conferred with counsel for Plaintiff by email and counsel for Data Scape Limited advised it is unopposed to the filing of this motion. /s/ J. Mark Mann J. Mark Mann CERTIFICATE OF SERVICE FOR FILINGS The undersigned hereby certifies that a true and correct copy of the above and foregoing documents has been served on June 14, 2019, by causing a copy thereof, to be sent electronically, through the ECF system to the registered participants in this cases, as identified on the Notice of Electronic Filing (NEF). /s/ J. Mark Mann J. Mark Mann 2