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`ESTTA Tracking number:
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`ESTTA1150350
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`Filing date:
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`07/31/2021
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`91251496
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`Party
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`Correspondence
`Address
`
`Plaintiff
`United States Polo Association Inc.
`
`DANIEL J BARSKY
`HOLLAND & KNIGHT LLP
`701 BRICKELL AVENUE SUITE 3300
`MIAMI, FL 33131
`UNITED STATES
`Primary Email: daniel.barsky@hklaw.com
`Secondary Email(s): Joanna.Crosby@hklaw.com, brian.murray@hklaw.com
`305-374-8500
`
`Submission
`
`Filer's Name
`
`Filer's email
`
`Stipulated/Consent Motion to Extend
`
`Daniel J. Barsky
`
`daniel.barsky@hklaw.com, joanna.crosby@hklaw.com,
`terry.mendoza@hklaw.com, ptdocketing@hklaw.com
`
`Signature
`
`Date
`
`/daniel j. barsky/
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`07/31/2021
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`Attachments
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`Consent Motion to Extend.pdf(131673 bytes )
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`TRADEMARK TRIAL AND APPEAL BOARD
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`
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`UNITED STATES POLO ASSOCIATION, INC.,
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`AMERICAN POLO ASSOCIATION, LLC,
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`v.
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`Opposer,
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`Applicant.
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`In the Matter of Trademark Application
`Nos: 88/194,367 and 88/194,367
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`For the Mark:
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`Publication Dates: July 9, 2019 and July
`16, 2019, respectively.
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`Opposition No.: 91251496
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`
`
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`CONSENT MOTION TO EXTEND DEADLINES
`
`
`Commissioner for Trademarks
`P.O. Box 1451
`Alexandria, VA 22313-1451
`
` Dear Sir or Madam:
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`Pursuant to Federal Rule of Civil Procedure 6(b), 37 C.F.R. § 2.120(a), Petitioner United
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`States Polo Association, Inc.., with the consent of Respondent American Polo Association, LLC,
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`hereby requests to extend deadlines in this case for 30 days to allow time for Petitioner to complete
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`its trial period. Despite the best efforts of the Parties, they were unable to schedule a mutually
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`convenient time to conduct the trial deposition of Applicant’s principal, Mr. Michael Farrah.
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`Petitioner requested deposition dates for Mr. Farrah on June 23, 2021 however counsel for
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`Applicant was out of the office and did not return until July 7, 2021. Due to scheduling conflicts
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`with Mr. Farrah and his counsel, they were able to offer only two dates during the entire 30-day
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`trial period for Mr. Farrah’s deposition; counsel for Petitioner had previously-scheduled
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`depositions on both of those dates. The Parties were ultimately able to identify three mutually
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`convenient dates for counsel and Mr. Farrah in August, however those dates all fell outside of
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`Plaintiff’s 30 day trial period.
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`Accordingly, the parties respectfully request to extend all deadlines by 30 days,
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`from the current deadlines, as follows:
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`Event
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`Current Deadline
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`Requested Deadline
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`Plaintiff’s Pretrial Disclosures Due
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`June 19, 2021
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`Closed, not modified.
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`Plaintiff’s 30-day Trial Period Ends
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`August 3, 2021
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`September 2, 2021
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`Defendant’s Pretrial Disclosures
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`August 18, 2021
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`September 17, 2021
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`Defendant’s 30-day Trial Period Ends
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`October 2, 2021
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`November 1, 2021
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`Plaintiff’s Rebuttal Disclosures Due
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`October 17, 2021
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`November 16, 2021
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`Plaintiff’s 15-day Rebuttal Period Ends November 16, 2021
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`December 16, 2021
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`Plaintiff’s Opening Brief Due
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`January 15, 2022
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`February 14, 2022
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`Defendant’s Brief Due
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`February 14, 2022
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`March 17, 2022
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`Plaintiff’s Reply Brief Due
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`March 1, 2022
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`April 1, 2022
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`
`
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`Dated: July 31, 2021
`
`
`
`
`
`
`
` /s/ Daniel J. Barsky
`Daniel J. Barsky, Esq.
`HOLLAND & KNIGHT LLP
`701 Brickell Avenue
`Suite 3300
`Miami, FL 33131
`(305) 374-8500
`daniel.barsky@hklaw.com
`
`
`Attorneys for Opposer United States Polo
`Association, Inc.
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`#85847272_v1
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that on July 31, 2021 I served a copy of the foregoing via electronic
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`mail on:
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`David N. Sharifi, Esq.
`Gabrielle Peters, Esq.
`L.A. TECH & MEDIA LAW FIRM
`11620 Wilshire Boulevard
`9th Floor
`Los Angeles, California 90025
`david@latml.com
`gpeters@latml.com
`301-757-0181
`Attorney for Applicant
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`/s/ Daniel J. Barsky
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`Daniel J. Barsky, Esq.
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`#85847272_v1
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`3
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