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Case 2:22-md-03034-TGB ECF No. 212, PageID.11966 Filed 01/04/24 Page 1 of 3
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`NEO WIRELESS, LLC
`
`v.
`
`AMERICAN HONDA MOTOR CO.
`INC. & HONDA DEVELOPMENT &
`MANUFACTURING OF AMERICA,
`LLC,
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`JOINT STIPULATION TO LIMITED EXTENSION
`OF FACT DISCOVERY DEADLINE
`Plaintiff Neo Wireless, LLC (“Neo”) and Defendants American Honda Motor
`
`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`
`Case No. 2:22-cv-11403-TGB
`HON TERRENCE G. BERG
`JURY TRIAL DEMANDED
`
`Co. and Honda Development & Mfg. Co. of America, LLC (“Honda”) jointly
`
`stipulate, subject to the approval of the Court, to a limited-purpose extension of the
`
`fact discovery deadline. Specifically, the parties ask that the Court approve a two-
`
`day extension through January 31, 2024, for the purpose of facilitating the deposition
`
`of Daniel Tiet, one of Honda’s 30(b)(6) designees. Good cause exists in that the
`
`proposed extension is necessary to accommodate Mr. Tiet’s schedule and the large
`
`number of other depositions taking place during the month of January in the above-
`
`captioned multidistrict litigation. The parties’ proposed extension would only apply
`
`to the deposition of Mr. Tiet, and would therefore only affect the individual case
`
`captioned above.
`
`1
`
`

`

`Case 2:22-md-03034-TGB ECF No. 212, PageID.11967 Filed 01/04/24 Page 2 of 3
`
`DATED: January 4, 2024
`
`Respectfully submitted,
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`Jaye Quadrozzi (P71646)
`Email: quadrozzi@youngpc.com
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, Michigan 48334
`Telephone: (248) 353-8620
`
`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on January 4, 2024January 4, 2024, the
`
`foregoing document was filed electronically with the Clerk of Court using the
`
`CM/ECF system, which will send notification of such filing to all attorneys of
`
`record.
`
`2
`
`

`

`Case 2:22-md-03034-TGB ECF No. 212, PageID.11968 Filed 01/04/24 Page 3 of 3
`
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`
`
`
`3
`
`

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