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Case 2:17-cv-00514-JRG Document 94-1 Filed 12/18/18 Page 1 of 3 PageID #: 3446
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`v.
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`HTC CORPORATION
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`Defendant.
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`LEAD CASE NO. 2:17-cv-514-JRG
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`MEMBER CASE NO. 2:17-cv-515-JRG
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC.
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`Defendant.
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`DECLARATION OF EDWARD R. TITTEL IN SUPPORT OF LG ELECTRONICS,
`INC.’S UNOPPOSED MOTION TO AMEND THE DOCKET CONTROL ORDER
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`I, Edward R. Tittel, state and declare as follows:
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`1.
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`I am a United States citizen and a resident of Texas, living at 2443 Arbor Drive
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`Round Rock, Texas 78681.
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`2.
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`I have been retained as the sole technical expert by Defendant LG Electronics,
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`Inc. (“LGEKR”) to respond to the expert opinion of Mr. Paul McAlexander, who is Plaintiff
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`AGIS Software Development, LLC’s (“AGIS”) expert on infringement issues. I understand that I
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`am also providing support for the LGEKR’s damages expert on technical issues implicated by
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`1
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`Case 2:17-cv-00514-JRG Document 94-1 Filed 12/18/18 Page 2 of 3 PageID #: 3447
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`and necessary to respond to the expert opinion of Mr. Alan Ratcliff, who is AGIS’s expert on
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`damages issues.
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`3.
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`I understand that AGIS served the opening expert reports of Messrs.
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`McAlexander and Ratcliff related to infringement and damages, respectively, the evening of
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`Friday, December 14, 2018. The next morning, on Saturday December 15, 2018, I received the
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`unfortunate and unexpected news that my father had passed away in Fairfax County, Virginia.
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`Although not yet obtained from the State of Virginia, if requested and necessary, I can furnish to
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`the Court a copy of my father’s death certificate once it is issued.
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`4.
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`In addition to the emotional toll I am enduring from my father’s passing, I am also
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`executor of his estate and will be handling his funeral and financial arrangements. This is very
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`important to me and it will also occupy a significant amount of time over the next several weeks
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`and into the new year.
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`5.
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`I understand that the current deadline under the Court’s schedule for serving
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`rebuttal reports is December 28, 2018. Respectfully, given this unanticipated event, my current
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`emotional state, and the related tasks for which I am now responsible, I am unable to realistically
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`and adequately meet this deadline.
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`6.
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`I realize the Court is very busy and responsible for many matters, but I would
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`humbly ask for an extension to January 18, 2019 so that I may adequately dedicate myself to
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`fulfilling my commitment to LGEKR and provide my expert rebuttal opinion in this matter. The
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`requested deadline of January 18, 2019 is requested by me not to delay matters since I know all
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`the litigants are waiting to review any opinion I may have in this case. In order to properly and
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`cogently go through the information in the case to give an accurate report, I need time that was
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`2
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`Case 2:17-cv-00514-JRG Document 94-1 Filed 12/18/18 Page 3 of 3 PageID #: 3448
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`not anticipated when this schedule was set out. I feel I need the time to emotionally and
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`physically prepare to do a good job considering the unexpected events that have occurred.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in
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`Round Rock, Texas on December 18, 2018.
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`Edward R. Tittel
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`3
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