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`June 9, 2023
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`Denise Alvarez
`Partner
`dalvarez@pashmanstein.com
`Direct: 201.270.4946
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`FILED AND SERVED VIA CM/ECF
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`Hon. Jessica S. Allen, U.S.M.J.
`U.S. District Court for the District of New Jersey
`Martin Luther King Building & U.S. Courthouse
`50 Walnut Street
`Newark, NJ 07101
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`Re:
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`Zirvi v. Illumina, Inc., et al., 2:23-cv-01997 (MCA) (JSA)
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`Dear Judge Allen:
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`This firm represents Defendants Akin Gump Strauss Hauer & Feld LLP and Matthew A.
`Pearson, Esq. (collectively, “Akin”) in the above-referenced matter. We write to request a brief
`extension of time for Akin to answer, reply, move, or otherwise respond to Plaintiff’s Complaint,
`which is currently due on June 14, 2023. Akin respectfully requests that the Court extend this
`deadline by twenty-seven days to July 11, 2023. Akin needs this extension due to the complexity
`of the issues raised in the Complaint. Granting this extension will also put Akin on the same
`schedule as co-defendants Illumina, Inc. and Thermo Fisher Scientific, who were served on April
`21 and April 26, 2023, and whose response deadline is also July 11, 2023. Akin was served on
`May 10, 2023.
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`We reached out to Plaintiff’s counsel multiple times to seek Plaintiff’s consent to the
`requested relief, but Plaintiff’s counsel has not responded. An extension to July 11 would not
`prejudice Plaintiff. This case is in the very early stages, and many defendants have not been served
`or entered an appearance. Further, none of the defendants have yet responded to the Complaint.
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`Accordingly, if the requested extension is acceptable to Your Honor, Akin respectfully
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`requests that the Court enter the enclosed Order extending Akin’s response deadline to July 11,
`2023.
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`Thank you for Your Honor’s attention to this matter.
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`cc: All Counsel of Record (via CM/ECF)
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`Respectfully submitted,
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`/s/ Denise Alvarez
`Denise Alvarez
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