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`SMART EXHIBIT 1011
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`Case 4:14-cv-01380 Document 7 Filed in TXSD on 08/15/14 Page 1 of 3
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`UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
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`JAMES B. GOODMAN,
`Plaintiff,
`vs.
`SMART MODULAR TECHNOLOGIES INC.
`Defendant.
`
`Civil Action No. 4:14-CV-01380 GHM
`
`Before U.S. District Court Judge
`GRAY H. MILLER
`JURY TRIAL DEMANDED
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`UNOPPOSED MOTION TO POSTPONE THE CONFERENCE DEADLINE
` OF AUGUST 27, 2014
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`Defendant respectfully submits this Unopposed Motion to Postpone the Conference
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`Deadline from August 27, 2014, to September 24, 2014, or sometime soon thereafter. The
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`Conference Deadline was set by the Order dated May 19, 2014.
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`The Defendant was properly served on August 7, 2014. The Parties have agreed that
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`Defendant has until September 18, 2014, to answer or otherwise respond.
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`Postponing the Conference will give the Defendant an opportunity to study the facts and
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`legal issues and answer or otherwise respond prior to the Conference.
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`The Defendant seeks this postponement for good cause so that justice can be served, and
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`not for delay.
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`SMART EXHIBIT 1011 - PAGE - 1
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`Case 4:14-cv-01380 Document 7 Filed in TXSD on 08/15/14 Page 2 of 3
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`Respectfully submitted,
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`/s/ Michael S. McCoy
`Michael S. McCoy
`Admission No. 24498
`TX State Bar No. 24013129
`King & Spalding
`1100 Louisiana, Suite 4000
`Houston, TX 77002
`Tel: 713-751-3218
`Fax: 713-751-3290
`mikemccoy@kslaw.com
`
`Michael F. Heafey
`King & Spalding
`601 South California Avenue # 100
`Palo Alto, CA 94304
`mheafey@kslaw.com
`Attorney in Charge
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`CERTIFICATE OF CONFERENCE
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`On or about August 15, 2014, I conferred with David Fink, counsel for Plaintiff, and was
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`informed that Plaintiff is unopposed to this Motion to Postpone the Conference Deadline from
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`August 27, 2014, to September 24, 2014, or sometime soon thereafter.
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`/s/ Michael S. McCoy
`Michael S. Mccoy
`
`2
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`SMART EXHIBIT 1011 - PAGE - 2
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`Case 4:14-cv-01380 Document 7 Filed in TXSD on 08/15/14 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing pleading has been sent by
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`prepaid First Class U.S. Mail on August 15, 2014, and by email to the Plaintiff’s attorney at:
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`David Fink
`Fink & Johnson
`7519 Apache Plume
`Houston, TX 77071
`Admission No. 299869
`Tel. 713 729-4991
`Fax: 713 729-4951
`Email: texascowboy6@gmail.com
`Attorney in Charge for the Plaintiff
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`/s/Michael S. McCoy
`Michael S. McCoy
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`3
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`SMART EXHIBIT 1011 - PAGE - 3