Nano Magic Inc. (NMGX)

[clydetheglide]

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
NANO-PROPRIETARY, INC., )
)
Plaintiff, )
)
v. ) Case No. 06-C-2689
)
TILL KEESMANN, JK PATENTPORTFOLIO ) Judge Wayne R. Anderson
GmbH & Co., JOCHEN KAMLAH, NPV )
NANO PATENT GmbH & Co. and )
ARNOLD AMSINCK, )
)
Defendants. )
AGREED MOTION FOR AN EXTENSION OF TIME
FOR NEW DEFENDANTS TO RESPOND TO AMENDED COMPLAINT
NOW COMES Defendants JK Patentportfolio, Jochen Kamlah, NPV Nano Patent, and
Arnold Amsinck (“Moving Defendants”), by and through undersigned counsel, and move this
Court to enter an Order granting them an extension, to and including August 10, 2007, in which
to file a response to Plaintiff’s Amended Verified Complaint (“Amended Complaint”). In
support of this Motion, Moving Defendants state as follows:
1. The Moving Defendants were added to this lawsuit by virtue of Plaintiff’s
Amended Complaint.
2. Undersigned counsel were recently retained by the Moving Defendants to
represent them in this matter.
3. The Moving Defendants are located in Germany and need additional time to
conduct an appropriate investigation of the factual and legal bases of the allegations in the
Amended Complaint in order to prepare a proper response thereto.
4. This Motion is not made for the purpose of delay, and Plaintiff will not be
prejudiced by the short extension requested.
5. Plaintiff’s counsel consents to this Motion.
WHEREFORE, Defendants JK Patentportfolio, Jochen Kamlah, NPV Nano Patent, and
Arnold Amsinck pray that this Honorable Court enter an Order granting them an extension, to
and including August 10, 2007, within which to file a response to the Amended Complaint.
Dated: June 29, 2007 Respectfully submitted,
JK Patentportfolio, Jochen Kamlah, NPV Nano
Patent, and Arnold Amsinck
By: __/s/ Derek S. Holland______________
One of Their Attorneys
Steven R. Smith, #3128231
Derek S. Holland, #6285564
Bryan Cave LLP
161 North Clark Street, Suite 4300
Chicago, Illinois 60601
Telephone: [phone]
Facsimile: [phone]
and
Mark Weinstein
White & Case
3000 El Camino Real
5 Palo Alto Square
Palo Alto, California 94306