Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Unopposed MOTION for Extension of Time to File Answer or Otherwise Respond to Bumble Trading Inc.'s Counterclaims by Match Group, LLC.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC § § § Plaintiff, § § No. 6:18-cv-00080-ADA v. § § BUMBLE TRADING INC. § JURY TRIAL DEMANDED § Defendant. § § § PLAINTIFF MATCH GROUP, LLC'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO BUMBLE TRADING INC.'S COUNTERCLAIMS Plaintiff Match Group, LLC ("Match") hereby files this Unopposed Motion for Extension of Time to Answer or Otherwise Respond to Bumble Trading Inc.'s ("Bumble") Counterclaims. In accordance with the parties' agreement, Bumble will soon file an unopposed motion for leave to amend its counterclaims to include additional allegations. See No. 6:18-cv-350 at Dkt. No. 68. Given that the new counterclaims would moot any motion to dismiss Bumble's current counterclaims, Match requests an extension to respond to the counterclaims until after Bumble has effectuated the contemplated amendment. The parties have met and conferred, and Bumble is unopposed to the relief requested herein. Match therefore respectfully requests that the Court grant this extension of time and that Match's response to Bumble's counterclaims be due 14 days after Bumble Trading, Inc. files its unopposed motion seeking to amend its counterclaims, as contemplated in 18-cv-350 Dkt. 68. DATED: March 1, 2019 Respectfully submitted, CALDWELL CASSADY & CURRY /s/ Bradley W. Caldwell Bradley W. Caldwell Texas State Bar No. 24040630 Email: John F. Summers Texas State Bar No. 24079417 Email: Warren J. McCarty, III Texas State Bar No. 24107857 Email: CALDWELL CASSADY CURRY P.C. 2101 Cedar Springs Road, Suite 1000 Dallas, Texas 75201 Telephone: (214) 888-4848 Facsimile: (214) 888-4849 John P. Palmer State Bar. 15430600 Email: Naman, Howell, Smith & Lee, PLLC 400 Austin Avenue, 8th Floor P.O. Box 1470 Waco, TX 76701 Telephone: (254) 755-4100 Facsimile: (254) 754-6331 ATTORNEYS FOR PLAINTIFF MATCH GROUP, LLC CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically with the Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel registered as Filing Users on this 1st day of March, 2019. /s/ Bradley W. Caldwell Bradley W. Caldwell 2