`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`
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`BLITZSAFE TEXAS, LLC,
`
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`Plaintiff,
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`
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`Case No. 2:15-CV-1274-JRG-RSP
`LEAD CASE
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`JURY TRIAL DEMANDED
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`§§§§§§§§§§§§§§§§
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`UNOPPOSED MOTION TO AMEND DOCKET CONTROL ORDER
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`COMES NOW Blitzsafe Texas, LLC (“Blitzsafe”) and files this Unopposed Motion to
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`Amend the Docket Control Order and respectfully shows the Court as follows:
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`On January 8, 2016 the court entered the Docket Control Order in this case (Dkt No. 56).
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`Under the current Order the parties are to complete mediation by July 22, 2106. The parties
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`agreed to use Judge David Folsom as the mediator in each case before the Court. The parties
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`coordinated with Judge Folsom’s office and were able to schedule all mediations in advance of
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`the July 22, 2016 deadline except for the mediation between Blitzsafe and Defendants
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`HYUNDAI MOTOR COMPANY, HYUNDAI MOTOR AMERICA, HYUNDAI MOTOR
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`MANUFACTURING, ALABAMA, LLC; KIA MOTORS CORPORATION, KIA MOTORS
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`AMERICA, INC., and KIA MOTORS MANUFACTURING GEORGIA, INC., (collectively
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`“Hyundai/Kia Defendants”) which has been scheduled for July 27, 2016. Due to Judge Folsom’s
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`HONDA MOTOR CO., LTD.;
`AMERICAN HONDA MOTOR CO.,
`INC.; HONDA OF AMERICA
`MANUFACTURING, INC.; HONDA
`MANUFACTURING OF ALABAMA,
`LLC; and HONDA MANUFACTURING
`OF INDIANA, LLC,
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`v.
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` Defendants.
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`Case 2:15-cv-01274-JRG-RSP Document 116 Filed 07/08/16 Page 2 of 3 PageID #: 2550
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`schedule and that of the parties, Blitzsafe and Hyundai/Kia were unable to schedule their
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`mediation within the current deadline contained in the current Docket Control Order. The parties
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`seek only to change the mediation deadline as it pertains to Blitzsafe and Hyundai/Kia as
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`follows:
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`Default Date
`(Current)
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`New Date
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`Proposed Date
`(if not the
`Default Date)
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`July 22, 2016
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`July 28, 2016
`(Hyundai/Kia)
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`Deadline to Complete Mediation
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`The parties are responsible for ensuring
`that a mediation report is filed no later
`than 5 days after the conclusion of
`mediation.
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`
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`The purpose of this amendment to the Docket Control Order is not for delay but so that
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`justice may be done.
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`WHEREFORE, PREMISES CONSIDERED, Blitzsafe respectfully requests this Court
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`grant this Unopposed Motion to Amend the Docket Control Order.
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`A proposed order is attached.
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`Dated: July 8, 2016
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`Respectfully submitted,
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`Samuel F. Baxter
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
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`
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`Case 2:15-cv-01274-JRG-RSP Document 116 Filed 07/08/16 Page 3 of 3 PageID #: 2551
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`Facsimile: (903) 923-9099
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`Alfred R. Fabricant
`Texas Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Lawrence C. Drucker
`Email: ldrucker@brownrudnick.com
`Texas Bar No. 2303089
`Peter Lambrianakos
`Texas Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: (212) 209-4800
`Facsimile: (212) 209-4801
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`was electronically filed with the CM/ECF system per LR 5.1, and that all interested parties are
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`being served with a true and correct copy of these documents via the CM/ECF system on July 8,
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`2016.
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`/s/ Jennifer Truelove
`Jennifer Truelove
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that I conferred with counsel for Hyundai/Kia. regarding the relief sought
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`in this Motion. Hyundai/Kia is not opposed to the relief sought in this Motion.
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`/s/ Jennifer Truelove
`Jennifer Truelove
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