UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
Hewlett-Packard Company,
Defendant.
Case No. 3:15-cv-00333-H-BGS
PLAINTIFF E.DIGITAL
CORPORATION’S UNOPPOSED
EX PARTE MOTION TO
EXTEND TIME FOR
DEFENDANT TO ANSWER OR
OTHERWISE RESPOND TO
THE COMPLAINT UNTIL
APRIL 27, 2015 OR WHATEVER
DATE THE COURT DEEMS
JUST AND REASONABLE
UNDER THE CIRCUMSTANCES
DEMAND FOR JURY TRIAL
Assigned to the Honorable
Judge Marilyn Huff
Courtroom 15A (15th Floor -
Annex)
Case 3:15-cv-00333-H-BGS Document 10 Filed 03/18/15 Page 1 of 4
EX PARTE MOTION RE: EXTENSION OF TIME Case No. 3:15-CV-00333-H-BGS

HANDAL & ASSOCIATES
750 B. STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
Pursuant to Local Civil Rule 12.1 and 7.2, Plaintiff e.Digital Corporation
(“Plaintiff”) hereby presents this ex parte motion for an order extending the time
for Defendant Hewlett-Packard Company (“Defendant”) to answer or otherwise
respond to the Complaint (“Complaint”). (Dkt #1). Plaintiff filed a Complaint in
this action against the Defendant on or about February 17, 2015. (Dkt #1).
Defendant has not appeared or otherwise responded to the Complaint in this case to
date. It is anticipated and believed that this motion is unopposed.
I. THE STATUS OF SERVICE UPON THE DEFENDANT
Plaintiff has caused to be served the Summons and Complaint upon
Defendant on or about March 5, 2015. (See, Dkt #9). Defendant’s response to the
Complaint is currently due on or before March 26, 2015.
II. BASIS FOR REQUEST FOR EXTENSION
Defendant’s counsel has requested an extension of time on behalf of
Defendant to respond to the Complaint. Plaintiff has agreed to this request. This
motion has been made in order to seek the Court’s approval of this agreement to
extend time as required by Local Civil Rule 12.1. Given that the Defendant or its
counsel have not yet appeared in this matter to date, this motion is made via an ex
parte motion by Plaintiff in accordance with the agreement reached by the parties
via their counsel.
Counsel for the Defendant has indicated that the Defendant needs additional
time to review the Complaint in this matter. Time is further needed for the parties
to discuss the possible resolution of this matter. If a resolution can be reached in
this matter, most likely such a resolution would be a global resolution that would
resolve this case in its entirety as to all the parties.
With the above in mind, Plaintiff seeks an extension of time for Defendant
to respond to the Complaint not for delay, but to, among other things, permit the
Case 3:15-cv-00333-H-BGS Document 10 Filed 03/18/15 Page 2 of 4
EX PARTE MOTION RE: EXTENSION OF TIME Case No. 3:15-CV-00333-H-BGS

HANDAL & ASSOCIATES
750 B. STREET
SUITE 2510
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
parties an opportunity to resolve Plaintiff’s claims without the need for further
litigation.
III. CONCLUSION
Accordingly, Plaintiff respectfully requests that Defendant be provided an
extension of time to answer or otherwise respond to the Complaint until April 27,
2015 or whatever date the Court deems just and reasonable under the
circumstances. Pursuant to Local Civil Rule 7.2, Plaintiff will separately submit a
Proposed Order granting the relief requested.
Dated: March 18, 2015
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk__________________
Anton N. Handal
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
e.Digital Corporation