`
`
`
`Ironside Newark
` 110 Edison Place, Suite 302
`Newark, New Jersey 07102
` Tel: 973.690.5400 Fax: 973.466.2761
`www.rwmlegal.com
`
`
`May 10, 2023
`
`
`VIA ECF
`Hon. Jessica S. Allen, U.S.M.J.
`United States District Court
`MLK Jr. Federal Bldg. and U.S. Courthouse
`50 Walnut Street
`Newark, NJ 07102
`
`
`Zirvi v. Illumina, Inc., et al.
`Re:
`2:23-cv-1997-MCA-JSA
`
`
`
`Dear Judge Allen:
`
`
`I represent Defendant Illumina, Inc. in the above-captioned matter. I am writing jointly on
`behalf of Illumina and Defendant Thermo Fisher Scientific (collectively “Moving Defendants”) to
`request a sixty (60) day extension to Answer or otherwise respond to the Complaint pursuant to
`Local Civil Rule 6.1. The time for Moving Defendants to respond to the Complaint has not yet
`expired and Moving defendants have not previously requested an extension.
`
`Moving Defendants requested consent from Plaintiff for a sixty (60) day extension but
`Plaintiff’s counsel would only consent to a thirty (30) day extension. Moving Defendants need a
`sixty day extension due to the number and complexity of the issues raised in the Complaint. There
`is no prejudice to Plaintiff because the lawsuit is still in its early stages and several other defendants
`have not yet been served or otherwise entered an appearance. Therefore, there is good cause for
`the requested extension.
`
`If the requested extension is acceptable to Your Honor, Moving Defendants respectfully
`request entry of the enclosed Order memorializing the extension request.
`
`We thank Your Honor for your attention to this matter and are available to discuss this
`request at the Court’s convenience.
`
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`cc: All counsel of record (via ECF)
`
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`Respectfully,
`
`
`
`
`s/ Keith J. Miller
` Keith J. Miller
`
`
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