`
`ESTTA Tracking number:
`
`ESTTA759788
`
`Filing date:
`
`07/21/2016
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91225358
`
`Party
`
`Correspondence
`Address
`
`Submission
`
`Filer's Name
`
`Filer's e-mail
`
`Signature
`
`Date
`
`Attachments
`
`Plaintiff
`Kind Management Inc.
`
`MARGARITA WALLACH
`MCCARTER & ENGLISH LLP
`245 PARK AVENUE, 27TH FLOOR
`NEW YORK, NY 10167
`UNITED STATES
`mwallach@mccarter.com, ihurtado@mccarter.com, apang@mccarter.com, ihur-
`tado@mccarter.com, apang@mccarter.com, dpopovic@mccarter.com
`
`Stipulated/Consent Motion to Extend
`
`Margarita Wallach, Esq.
`
`mwallach@mccarter.com, apang@mccarter.com, ihurtado@mccarter.com,
`dlynch@mccarter.com
`
`/mw/
`
`07/21/2016
`
`Opposition No. 91225358 7.21.16 Consented Motion to Extend.pdf(119958
`bytes )
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In the matter of Application
`Serial No. 86/512,966
`
`January 23, 2015
`Filed:
`For the mark: NATIVE KIND
`
`Published: June 16, 2015
`
`KIND MANAGEMENT INC.,
`
`:
`
`OPPOSITION NO. 91225358
`
`Opposer,
`
`v.
`
`APRIL VALENCIA,
`
`Applicant.
`
`Commissioner for Trademarks
`
`United States Patent and Trademark Office
`
`Trademark Trial and Appeal Board
`PO. Box 1451
`
`Alexandria, VA 22313 -1451
`
`MOTION ON CONSENT TO EXTEND INITIAL DISCLOSURES, DISCOVERY AND
`TRIAL PERIODS
`
`Opposer KIND Management Inc. (“Opposer”), requests that all deadlines in this proceeding be
`
`extended for thirty (30) days to allow the parties to continue settlement efforts. The parties have held a
`
`discovery conference and are in the process of discussing potential settlement terms. The parties hereby
`
`request that all deadlines in this proceeding, including the deadline for the initial disclosures, expert
`
`disclosures, close of discovery and all trial dates, be extended for thirty (30) days in order to allow the
`
`parties additional time to pursue settlement in this matter.
`
`The deadline for the parties to serve initial disclosures is currently scheduled for July 22, 2016
`
`and the close of discovery is currently scheduled for December 19, 2016. Opposer requests that such
`
`dates be extended for thirty (30) days, or until August 21, 2016 and January 18, 2017, respectively, and
`
`ME] 22915735v.2
`
`
`
`that all subsequent dates be reset accordingly. Opposer proposes that the revised schedule for the
`
`proceedings be as follows:
`
`Initial Disclosures Due :
`
`Expert Disclosures Due :
`
`Discovery Period to Close :
`
`Plaintiff Pretrial Disclosures :
`
`Plaintiffs 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 :
`
`08/21/2016
`
`12/19/2016
`
`01/18/2017
`
`03/04/2017
`
`04/18/2017
`
`05/03/2017
`
`06/18/2017
`
`07/02/2017
`
`08/01/2017
`
`Applicant APRIL VALENCIA consented to this motion, which is requested to allow the
`
`parties time to continue settlement discussions, and prepare and execute a written settlement
`
`agreement.
`
`Based on the foregoing, the parties respectfully request that the initial disclosures
`
`deadline and the discovery and trial periods be extended by thirty (30) days and reset
`
`accordingly, as set forth above.
`
`ME1229l5735v.2
`
`
`
`This request is not made for purposes of delay.
`
`Dated: July 21, 2016
`
`Respectfully submitted,
`McCarter & English, LLP
`
`By:
`
`/Margarita Wallach/
`Margarita Wallach
`Attorney for Opposer
`KIND Management Inc.
`
`McCurter I'Cnglish, LLP
`245 Park Ave, 27th Hour
`
`New York, NY 10167
`Tel: (212) 609-6800
`Fax: (212) 609-6921
`
`MEI 22915735v2
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and complete copy of the foregoing Motion On Consent To
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`Extend Initial Disclosures, Discovery And Trial Periods was served on the Applicant, by First
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`Class Mail, at the following address:
`
`Teresa Lee
`
`Pryor Cashman LLP
`7 Times Square
`New York, NY 10036-6569
`
`Dated: June 21, 2016
`
`
`
`anielle Lynch
`
`ME] 22915735v.2
`
`
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