Assented to Motion for Extension of Time to May 21, 2026 to File Responsive Pleading and Rule 12 Motion by Staples, Inc..(Goodwin, Samuel)

Document #6 Filed 04/16/2026 · 3 pages · District Court, D. Massachusetts · View original PDF

1On March 29, 2026, Plaintiff filed the Complaint in this action. (Docket No. 1).

2On March 31, 2026, Plaintiff served the Complaint, and Staples’ Answer is currently due April 21, 2026. (Docket No. 4).

3Staples requires additional time to complete its internal investigation into the factual allegations set forth in Plaintiff’s Complaint. Additionally, counsel for Staples was recently retained in the instant action, and as such, incoming counsel also requires additional time to review the relevant facts and applicable law to determine the proper response to the allegations in Plaintiff’s Complaint.

4No scheduling order has been entered in this action and no discovery is presently pending or scheduled.

5Staples expects to file its responsive pleading or Rule 12 motion on or before May 21, 2026.

6On April 16, counsel for Staples who will be applying to appear pro hac vice (listed below) conferred via telephone with Plaintiff’s counsel regarding the requested extension of time to respond. Plaintiff’s counsel has consented to this motion for an extension of time up to and including May 21, 2026.

CONCLUSION

WHEREFORE, Staples respectfully requests that the Court extend the deadline for its responsive pleading and Rule 12 motion to May 21, 2026.

Respectfully submitted, STAPLES, INC. By its attorneys, /s/ Samuel B. Goodwin Samuel B. Goodwin (BBO # 699138) DEMEO, LLP 66 Long Wharf Boston, MA 02110 Tel: (617) 263-2600 [email protected] Lauri Mazzuchetti (pro hac vice forthcoming) Whitney Smith (pro hac vice forthcoming) Kelley Drye & Warren LLP 7 Giralda Farms, Suite 340 Madison, NJ 07940 Telephone: 973.503.5900 Frances McDonald (pro hac vice forthcoming) Kelley Drye & Warren LLP 3 Word Trade Center 175 Greenwich Street New York, NY 10007 Telephone: 212.808.5040

Dated: April 16, 2026

LOCAL RULE 7.1 CERTIFICATION

I, Samuel B. Goodwin, hereby certify that on April 16, 2026, counsel for Staples who are listed above as “pro hac vice forthcoming” communicated with Plaintiff’s counsel via telephone, and Plaintiff’s counsel has assented to the relief requested herein.

/s/ Samuel B. Goodwin Samuel B. Goodwin CERTIFICATE OF SERVICE

I hereby certify that, on the above date, a true and correct copy of the foregoing document was served through the Court’s electronic filing system.

/s/ Samuel B. Goodwin Samuel B. Goodwin

Transcribed from the public court filing · view original PDF

Public U.S. federal court record (district court docket 73109355, document 6). Source via the RECAP Archive (Free Law Project). The same record is available from PACER. Informational only — not legal advice.