e.Digital Corporation v. Verbatim America, LLC

01/23/2014 11 Ex Parte MOTION for Extension of Time to File Answer Plaintiff e.Digital

Corporations Unopposed Ex Parte Motion To Extend Time For Defendant To

Respond To The Complaint Until March 20, 2014 Or Whatever Date The Court

Deems Just And Reasonable Under The Circumstances by e.Digital Corporation.

(Attachments: # 1 Declaration Declaration of Pamela C. Chalk)(Chalk, Pamela)

(ag). (Entered: 01/23/2014)

Docket: https://drive.google.com/file/d/0Bx9NLDCScshnWVZSY2FmTWQ4cnM/edit?usp=sharing

Document 11: https://drive.google.com/file/d/0Bx9NLDCScshnLU5NNVU4UzZPa2s/edit?usp=sharing

BASIS FOR REQUEST FOR EXTENSION

Counsel for the Defendant has indicated that the Defendant needs additional time to review the Complaint in this matter and to retain local counsel. Counsel for the Defendant has also indicated a willingness to discuss settlement of this matter. Time is needed for the parties to discuss the possible resolution of this matter. If a resolution can be reached in this matter, most likely such a resolution would be a global resolution that would resolve this case in its entirety as to all the parties.

With the above in mind, Plaintiff seeks an extension of time for Defendant to respond to the Complaint not for delay, but to, among other things, permit the parties an opportunity to resolve Plaintiff’s claims without the need for further litigation.