Case 3:13-cv-04314-P Document 10 Filed 11/22/13

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION MAGIC BULLET RECORDS, LLC, RAYMOND BROWN, JEREMY GALINDO, AND CHRISTOPHER KING, Plaintiffs vs. E3 PARTNERS MINISTRY, AUDIO POST GROUP, LP, BRAD DALE, AND DITORE-MEO ENTERTAINMENT COMPANY, Defendants.

CIVIL ACTION NO. 3:13-CV-4314

DEFENDANT E3 PARTNERS MINISTRYS UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFFS ORIGINAL COMPLAINT Defendant E3 Partners Ministry (E3), files this Unopposed Motion for Extension of Time to Answer, Move or Otherwise Respond to Plaintiffs Magic Bullet Records, LLC, Raymond Brown, Jeremy Galindo, and Christopher King Stevens (Plaintiffs) Original Complaint. Counsel for Plaintiffs agrees to the extension and is not opposed to this motion. Plaintiffs sued Defendant for copyright infringement and served E3 on November 1, 2013. E3s deadline to answer or file other responsive pleading is November 22, 2013. E3 has requested, and Plaintiffs have agreed to, an extension of time of 83 days, i.e., until February 12, 2014, in which to respond to the Complaint. Good cause exists for granting this motion as E3 requires additional time for counsel to adequately confer with the other defendants and to prepare its response to the Complaint. In addition, the Plaintiffs and E3 are currently in negotiations in an attempt to settle this matter and avoid burdening this Court with complex and costly litigation.

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As a part of this negotiation, E3 and the Plaintiffs are trying to engage in mediation prior to February 12, 2014. However, since the parties will be trying to coordinate the schedule of the mediator, at least 5 attorneys, 8 clients, and the possible involvement of insurance carriers, it is unlikely that mediation can be scheduled and completed prior to the holiday season. The impact on the court caused by this delay is minimal because it will improve the chances that the parties will be able to settle this dispute without taking up the courts resources. E3 requests this extension in good faith, and does not request the extension to cause undue delay but for good cause and that justice may be served. As such, E3 respectfully requests that its time to answer, move or otherwise respond to Plaintiffs Original Complaint be extended up to and including February 12, 2014. Respectfully submitted,

/s/ William B. Nash William B. Nash State Bar No. 14812200 Laura Lee Prather State Bar No. 16234200 Catherine Lewis Robb State Bar No. 24007924 HAYNES AND BOONE, LLP 112 East Pecan Street, Suite 1200 San Antonio, TX 78205 Telephone: (210) 978-7477 Facsimile: (210) 554-0484 E-mail: bill.nash@haynesboone.com ATTORNEYS FOR E3 PARTNERS MINISTRY

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CERTIFICATE OF CONFERENCE I hereby certify that I conferred with David Lein, counsel for all Plaintiffs, regarding the foregoing Motion for Extension of Time. Mr. Lein indicated that he agrees with the extension of time and does not oppose the Motion. E3, therefore, submits the Motion as unopposed. /s/ William B. Nash William B. Nash

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the following parties via ECF, this 22nd day of November, 2013: /s/ William B. Nash William B. Nash David P. Lein Graves, Dougherty, Hearon & Moody, P.C. 401 Congress Avenue, Suite 2200 Austin, TX 78701 Telephone: (512) 480-5717 Telecopier: (512) 536-9917

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