UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
Project Honey Pot, a dba of Unspam
Technologies, Inc.,
Plaintiff,
v.
John Does,
Defendants.
NOTICE OF MOTION AND MOTION TO EXTEND TIME TO CONDUCT DISCOVERY NECESSARY TO IDENTIFY AND SERVE DEFENDANTS, AND TO EXTEND RULE 4(M) DEADLINE TO NAME AND SERVE DEFENDANTS
PLEASE TAKE NOTICE that on December 7, 2007 at 10:00 a.m., or as soon thereafter as the matter may be heard, Plaintiff Project Honey Pot (“PHP”), by its counsel, will present oral argument in support of its Motion to Extend Time to Conduct Discovery Necessary to Identify and Serve Defendants, and to Extend Rule 4(m) Deadline to Name and Serve Defendants.
Pursuant to Federal Rules of Civil Procedure 4(m) and 26(d), PHP hereby moves the Court to extend the time to conduct discovery necessary to identify and serve, and to extend the deadline to name and serve the John Doe Defendants. PHP has submitted a short Memorandum in support of its Motion.
Dated: November 26, 2007
Respectfully submitted,
/s/
Jon L. Praed
VSB #40678
Attorney for Plaintiff Project Honey Pot