`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`
`NEO WIRELESS, LLC,
`
`
`Plaintiff,
`
`
`Case No. 2:22-md-03034-TGB
`Hon. Terrence G. Berg
`
`
`
`
`Case No. 2:22-CV-11769-TGB
`Hon. Terrence G. Berg
`
`
`
`
`
`
`MERCEDES-BENZ USA, LLC
`
`
`v.
`
`Defendant.
`
`
`
`
`
`
`STIPULATION TO EXTEND MERCEDES-BENZ USA, LLC’S DEADLINE TO
`RESPOND TO THE COMPLAINT
`
`Defendant Mercedes-Benz USA, LLC (“MBUSA”) and Plaintiff Neo Wireless, LLC.
`
`(“Neo”), hereby respectfully stipulate, subject to approval of the Court, as follows:
`
`On July 15, 2022, Neo filed its Complaint in the United States District Court for the Middle
`
`District of Florida. Dkt. 1.1 On July 19, 2022, MBUSA was served with the Complaint, Dkt. 8. On
`
`August 1, 2022, the United States Judicial Panel on Multidistrict Litigation entered a Conditional
`
`Transfer Order transferring Neo’s case against MBUSA to the Eastern District of Michigan for further
`
`proceedings. Dkt. 9.
`
`Given the Conditional Transfer Order, among other things, MBUSA and Neo have agreed
`
`that MBUSA’s deadline to respond to the Complaint by answer and/or motion should be extended
`
`
`1 Citations are to the original case Neo filed against MBUSA, captioned as Neo Wireless, LLC v.
`Mercedes-Benz USA LLC, No. 22-cv-780 (M.D. Fla.)
`
`
`
`Case 2:22-md-03034-TGB ECF No. 49, PageID.2078 Filed 08/09/22 Page 2 of 3
`
`to September 12, 2022. MBUSA agrees that it will not use this extension as a basis to delay or
`
`decline participation in discovery or scheduling matters, including the upcoming scheduling
`
`conference with the Court.
`
`Respectfully submitted,
`/s/ Celine J. Crowson
`Celine J. Crowson
`Joseph J. Raffetto
`Hogan Lovells US LLP
`555 Thirteenth St, NW
`Washington, DC 20004
`Telephone: (202) 637-5703
`Facsimile: (202) 637-5910
`Email: celine.crowson@hoganlovells.com
`Email: joseph.raffetto@hoganlovells.com
`
`Counsel for Defendant Mercedes-Benz USA,
`LLC
`
`Dated: August 9, 2022
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`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)
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, MI 48334
`Telephone: (248) 353-8620
`Email: quadrozzi@youngpc.com
`
`ATTORNEYS FOR PLAINTIFF NEO
`WIRELESS, LLC
`
`2
`
`
`
`Case 2:22-md-03034-TGB ECF No. 49, PageID.2079 Filed 08/09/22 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I certify that on August 9, 2022, I electronically filed the foregoing with the Clerk of the
`
`Court using the CM/ECF system which will send notification of such filing to all counsel of
`
`record.
`
`/s/ Celine J. Crowson
`Celine J. Crowson
`
`
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