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`Case 5:20-cv-05676-EJD Document 18 Filed 09/11/20 Page 1 of 2
`
`
`
`IRELL & MANELLA LLP
`Benjamin W. Hattenbach (186455)
`BHattenbach@irell.com
`C. Maclain Wells (221609)
`MWells@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`Attorneys for Defendant
`DEMARAY LLC
`
`APPLIED MATERIALS, INC.,
`
`
`Plaintiff,
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case No. 5:20-cv-05676-EJD
`
`DEMARAY LLC’S UNOPPOSED
`MOTION FOR EXTENSION OF TIME
`TO RESPOND TO APPLIED
`MATERIALS’ MOTION FOR
`PRELIMINARY INJUNCTION
`
`
`
`
`DEMARAY LLC,
`
`
`vs.
`
`Defendant.
`
`
`
`
`Defendant Demaray LLC (“Demaray”) hereby moves under Local Rule 6-3 to extend the
`time within which it is required to respond to Plaintiff Applied Materials, Inc.’s (“Applied
`Materials”) Motion for Preliminary Injunction to September 25, 2020. Applied Materials filed its
`Motion for Preliminary Injunction on Friday, September 4 (Dkt. 14) and provided an email copy
`of its motion and supporting papers to counsel for Demaray that evening requesting agreement to
`email service. Declaration of C. Maclain Wells (“Wells Decl.”), ¶ 2. Given the holiday weekend,
`counsel for Demaray responded on Wednesday, September 9, agreeing to accept service of the
`motion. Id.
`Given the timing of Applied Materials’ motion, the intervening holiday, the location of
`individuals involved and the issues raised in Applied Materials’ September 1, 2020, First
`
`10876484
`
`
`
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME
`
`
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`Case 5:20-cv-05676-EJD Document 18 Filed 09/11/20 Page 2 of 2
`
`Amended Complaint and Applied Materials’ Preliminary Injunction Motion, Demaray seeks an
`extension of time to file its opposition to September 25. Id., ¶ 3. In particular, Demaray has just
`two weeks to prepare its response under the timeframes provided under the Local Rules and would
`be prejudiced by being required to attempt to marshal information required to fully respond in the
`provided timeframe. Id. There have been no other extensions of time in this matter. Id., ¶ 4.
`Applied Materials’ motion is noticed for hearing on November 12, 2020. Dkt. 15. The requested
`extension will not impact the noticed hearing date. Id. The parties have met and conferred and
`Applied Materials has agreed to the extension.
`For the foregoing reasons, Demaray requests that the Court grant this motion and issue an
`order extending the deadline for Demaray to respond to Applied Materials’ motion to September
`25, 2020. Applied Materials does not oppose this motion.
`
`Dated: September 11, 2020
`
`
`
`Respectfully submitted,
`IRELL & MANELLA LLP
`
`
`
`10876484
`
`
`By: /s/ C. Maclain Wells
`C. Maclain Wells
`Attorneys for Defendant DEMARAY LLC
`
`- 2 -
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME
`
`
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