`ESTTA540858
`ESTTA Tracking number:
`05/30/2013
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91188676
`Plaintiff
`Chicago National League Ball Club, LLC
`Defendant
`COOGI Partners, LLC
`Yes
`
`Proceeding.
`Applicant
`
`Other Party
`
`Have the parties
`held their
`discovery
`conference as
`required under
`Trademark Rules
`2.120(a)(1) and
`(a)(2)?
`
`Motion for an Extension of Answer or Discovery or Trial Periods With
`
`The Close of Plaintiff's Trial Period is currently set to close on 08/24/2013. Chicago National League Ball
`Club, LLC requests that such date be extended for 30 days, or until 09/23/2013, and that all subsequent
`dates be reset accordingly.
`
`Consent
`
`Time to Answer :
`Deadline for Discovery Conference :
`Discovery Opens :
`Initial Disclosures Due :
`Expert Disclosure Due :
`Discovery Closes :
`Plaintiff's Pretrial Disclosures :
`Plaintiff's 30-day Trial Period Ends :
`Defendant's Pretrial Disclosures :
`Defendant's 30-day Trial Period Ends :
`Plaintiff's Rebuttal Disclosures :
`Plaintiff's 15-day Rebuttal Period Ends :
`
`CLOSED
`CLOSED
`CLOSED
`CLOSED
`CLOSED
`CLOSED
`08/09/2013
`09/23/2013
`10/08/2013
`11/22/2013
`12/07/2013
`01/06/2014
`
`The grounds for this request are as follows:
`- Parties are unable to complete discovery/testimony during assigned period
`- Parties are engaged in settlement discussions
`- The parties are engaged in the discovery process. Applicant served its requests on April 17, 2013 and
`Opposer served its requests on May 23, 2013. However, due to the massive amount of materials that will
`need to be gathered, covering an extensive period of time, the parties need additional time to complete
`the exchange of discovery. (Additionally, while engaged in discovery, the parties have also had
`substantive settlement discussions, and a revised draft agreement is now being reviewed by Applicant#s
`counsel.) The parties therefore request that the trial periods be extended for 30 days in order to allow time
`for the completion of the exchange of discovery before entering the trial periods.
`Chicago National League Ball Club, LLC has secured the express consent of all other parties to this
`
`
`
`proceeding for the extension and resetting of dates requested herein.
`Chicago National League Ball Club, LLC has provided an e-mail address herewith for itself and for the
`opposing party so that any order on this motion may be issued electronically by the Board.
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by First Class Mail on this date.
`Respectfully submitted,
`/Maryann E. Licciardi/
`Maryann E. Licciardi
`mel@cll.com, trademark@cll.com, jmn@cll.com
`pvranum@gordonherlands.com
`05/30/2013
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