Calypso Wireless (fka CLYW)

[conagra]

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

CALYPSO WIRELESS, INC.,
Plaintiff,
and
DRAGO DAIC,
Co-Plaintiff and Cross-Claim Defendant,
and
JIMMY WILLIAMSON, PC, and
KELLY D. STEPHENS,
Third-Party Defendants,
v.
T-Mobile USA, Inc.
Defendant.

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Case No. 2:08-CV-00441
Jury Demanded
UNOPPOSED MOTION FOR EXTENSION OF DEADLINE TO RESPOND TO MOTION TO DISMISS

Calypso Wireless, Inc. (“Calypso”) and Drago Daic hereby request that the Court extend the deadline for Calypso and Daic to file a response to T-Mobile USA, Inc.’s (“T-Mobile”) Motion to Dismiss (Docket No. 109). The current deadline, under Local Rules CV-6 and CV-7 is Thursday, February 17, 2010. Counsel for Calypso conferred with counsel for T-Mobile, who indicated that T-Mobile consents to an extension of three days to Tuesday, February 23, 2010.

Dated: February 17, 2010 Respectfully submitted,
/s/ Anthony Miller
Paul V. Storm (lead counsel)
[e-mail]
State Bar No. 19325350
Anthony P. Miller
[e-mail]
State Bar No. 24041484
Michael Leach
[e-mail]
State Bar No. 24065598
Storm LLP
901 Main Street, Suite 7100
Phone: [phone]
Fax: [phone]
ATTORNEYS FOR CALYPSO
WIRELESS, INC.

Agreed to by:
/s Timothy W. Johnson s/
Guy E. Matthews (lead counsel)
State Bar No. 13207000
Timothy W. Johnson
State Bar No. 24002366
Matthew C. Juren
State Bar No. 24065530
Matthews, Lawson & Bowick, PLLC
2000 Bering Drive, Suite 700
Houston, Texas 77057
[phone] (Telephone)
[phone] (Facsimile)
Email: [e-mail]
[e-mail]
[e-mail]
ATTORNEYS FOR PLAINTIFF
JIMMY WILLIAMSON, P.C.


CERTIFICATE OF CONFERENCE
I hereby certify that on February 17, 2010, I conferred via e-mail with Anne Champion, counsel for Defendant T-Mobile USA, Inc. to request an extension of the February 18, 2010 deadline to respond to T-Mobile’s Motion to Dismiss (Docket No. 109) to February 23, 2010. Ms. Champion indicated that T-Mobile consents to this extension.

/s/ Anthony Miller
Anthony Miller