Case 1:10-cv-00974-RJL Document 5 Filed 10/29/10 Page 1 of 2

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UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF COLUMBIA

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DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) Civil Action No. 10-974(RJL).
)

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INGRAM CONTENT GROUP INC., et al., )
)
Defendants. )
)

PLAINTIFFS’ MOTION TO EXTEND TIME TO SERVE DEFENDANTS

AND MEMORANDUM IN SUPPORT
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Pursuant to Fed. R. Civ. P. 4(m), plaintiffs, Daniel Parisi, Whitehouse.com Inc.,

Whitehouse Network LLC, and White House Communications Inc. (collectively referred to as

“plaintiffs”), by counsel, hereby move for an extension of time to January 15, 2011 to serve the

summons and complaint on defendants, Ingram Content Group Inc. and Lightning Source Inc.
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(collectively referred to as “defendants”). In support of this motion, plaintiffs state as follows:

Plaintiffs filed the complaint in the action on June 10, 2010. They have not yet served

the defendants. The parties have been engaged in communications and discussions to attempt to

resolve this case. Plaintiffs want to ensure, however, that the action is not dismissed for failure
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to effect timely service.

Fed. R. Civ. P. 4(m) provides, in relevant part, that:

If a defendant is not served within 120 days after the

complaint is filed, the court — on motion or on its own after notice
to the plaintiff — must dismiss the action without prejudice against
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that defendant or order that service be made within a specified

time. But if the plaintiff shows good cause for the failure, the court
must extend the time for service for an appropriate period.

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 Case 1:10-cv-00974-RJL Document 5 Filed 10/29/10 Page 2 of 2

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Plaintiffs respectfully request an extension of time to January 15, 2010 to serve the

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summons and complaint on defendants. Attempts to resolve a dispute without the need for

judicial intervention is good cause to grant the requested extension.

A proposed order is attached.

Dated: October 29, 2010 Respectfully submitted,

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/s/ Richard J. Oparil
Richard J. Oparil (D.C. Bar No. 409723)
PATTON BOGGS LLP
2550 M Street, NW
Washington, DC 20037
(202) 457-6000
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Attorneys for Plaintiffs

Of Counsel:

Kevin M. Bell (Bar No. 14382)

PATTON BOGGS LLP
8484 Westpark Drive
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McLean, VA 22102
(703) 744-8000
(703) 744-8001 (fax)

5129413
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 Case 1:10-cv-00974-RJL Document 5-1 Filed 10/29/10 Page 1 of 1

t
UNITED STATES DISTRICT COURT

.ne
FOR THE DISTRICT OF COLUMBIA

)
DANIEL PARISI, et al., )
)
Plaintiffs, )
)
v. ) Civil Action No. 10-974(RJL).
)

tor
INGRAM CONTENT GROUP INC., et al., )
)
Defendants. )
)

ula PROPOSED ORDER

Upon consideration of the motion of plaintiffs, Daniel Parisi, Whitehouse.com Inc.,

Whitehouse Network LLC, and White House Communications Inc. (collectively referred to as

“plaintiffs”), pursuant to Fed. R. Civ. P. 4(m), for an extension of time to January 15, 2011 to

serve the summons and complaint on defendants, Ingram Content Group Inc. and Lightning

Source Inc., it is hereby

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ORDERED that plaintiffs’ motion for an extension of time to January 15, 2011 is hereby

GRANTED.
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SO ORDERED this ________ day of ________________, 2010.

UNITED STATES DISTRICT JUDGE

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