`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF SOUTH CAROLINA
`GREENVILLE DIVISION
`
`
`
`
`ZIPIT WIRELESS, INC.,
`
`
`
`
`
`LG ELECTRONICS, INC.
`
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`Defendant.
`
` Case No. 6:18-cv-02016-JMC
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`
`
`
`
`
`
`
`
`JOINT MOTION TO EXTEND THE DEADLINE FOR LIMITED
`JURISDICTIONAL DISCOVERY BY TWO MONTHS
`
`Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Plaintiff Zipit Wireless, Inc.
`
`(“Plaintiff”) and Defendant LG Electronics, Inc. (“Defendant”) (together, the “Parties”) jointly
`
`move this Court to extend the deadline for completing limited jurisdictional discovery by two (2)
`
`months, and in support thereof state as follows:
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`1.
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`On September 19, 2019 the Court granted Plaintiff’s request for limited
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`jurisdictional discovery and allowed the Parties ninety (90) days of discovery on issues relevant to
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`the Court’s personal jurisdiction over Defendant. (Dkt. 60).
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`2.
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`3.
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`The ninety (90) discovery period is presently set to expire December 18, 2019.
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`The Parties seek a two (2) month extension of the limited discovery period, or until
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`February 18, 2019, to further consider and complete the limited discovery.
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`4.
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`5.
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`6.
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`This requested extension of time is the Parties first request for an extension of time.
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`The Parties request this extension of time in good faith.
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`Counsel for the Parties have conferred, and the Parties make this motion jointly and
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`
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`6:18-cv-02016-JMC Date Filed 11/25/19 Entry Number 71 Page 2 of 4
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`by consent.
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`The Parties therefore respectfully request that the Court enter an Order extending the
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`limited discovery period for two (2) months, or until February 18, 2020. A proposed order is
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`attached for the Court’s convenience.
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`Respectfully submitted this 25th day of November, 2019.
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`/s/ Robert P. Foster
`
`Robert P. Foster
`FOSTER LAW FIRM, LLC
`601 East McBee Avenue
`Suite 104
`Greenville, SC 29601
`Telephone: (864) 242-6200
`Facsimile: (864) 233-0290
`Email: rfoster@fosterfoster.com
`
`Stephen R. Risley
`(admitted pro hac vice)
`KENT & RISLEY LLC
`5755 North Point Parkway, Suite 57
`Alpharetta, GA 30022
`Telephone: (404) 585-2101
`Facsimile: (678) 389-9402
`Email: steverisley@kentrisley.com
`
`Daniel A. Kent
`(admitted pro hac vice)
`KENT & RISLEY LLC
`5755 North Point Parkway, Suite 57
`Alpharetta, GA 30022
`Telephone: (404) 585-4214
`Facsimile: (404) 829-2412
`Email: dankent@kentrisley.com
`
`Cortney S. Alexander
`(admitted pro hac vice)
`KENT & RISLEY LLC
`5755 North Point Parkway, Suite 57
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`
`
`
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`
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`
`
`/s/ Keith D. Munson
`
`Keith D. Munson (Fed. ID No. 6843)
`Email: Keith.munson@wbd-us.com
`WOMBLE BOND DICKINSON (US) LLP
`550 South Main Street, Suite 400
`Greenville, South Carolina 29601
`Telephone: (864) 255-5412
`Facsimile: (864) 239-5480
`
`Michael S. Kwun (pro hac vice)
`mkwun@kblfirm.com
`Asim M. Bhansali (pro hac vice)
`abhansali@kblfirm.com
`Kate E. Lazarus (pro hac vice)
`klazarus@kblfirm.com
`KWUN BHANSALI LAZARUS LLP
`555 Montgomery Street
`Suite 750
`San Francisco, CA 94111
`Telephone: (415) 630-2350
`Facsimile: (415) 367-1539
`
`Attorneys for Defendant,
`LG Electronics, Inc.
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`2
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`
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`6:18-cv-02016-JMC Date Filed 11/25/19 Entry Number 71 Page 3 of 4
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`Alpharetta, GA 30022
`Telephone: (404) 855-3867
`Facsimile: (770) 462-3299
`Email: cortneyalexander@kentrisley.com
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`Attorneys for Plaintiff,
`Zipit Wireless, Inc.
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`3
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`6:18-cv-02016-JMC Date Filed 11/25/19 Entry Number 71 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I certify that on November 25, 2019 the above and foregoing document was electronically
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`
`
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`filed with the Clerk of Court for the United States District Court for the District of South Carolina,
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`Greenville Division, using the CM/ECF system, which will automatically send notification of such
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`filing to counsel Record.
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`/s/ Robert P. Foster
`Robert P. Foster
`FOSTER LAW FIRM, LLC
`601 East McBee Avenue
`Suite 104
`Greenville, SC 29601
`Telephone: (864) 242-6200
`Facsimile: (864) 233-0290
`Email: rfoster@fosterfoster.com
`
`
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`
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`
`4
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`
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