`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`Civil Action No. 2:17-CV-516-JRG
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`JOINT MOTION FOR EXTENSION OF TIME TO FILE PROTECTIVE ORDER AND
`E-DISCOVERY ORDER
`
`Plaintiff AGIS Software Development LLC, (“AGIS”) and Defendant Apple Inc.
`
`(“Apple”), jointly and respectfully request the Court to extend the time within which the parties
`
`are required to submit a proposed protective order and E-Discovery Order and show the Court as
`
`follows:
`
`Pursuant to this Court’s Sample Docket Control Order, the deadline to file a Protective
`
`Order was October 11, 2017. On October 4, 2017, the parties filed a Joint Motion for Extension
`
`of Time to File Protective Order (DKT37) requesting a one-week extension of up to and through
`
`October 18, 2017, which is pending before the Court. The Parties are continuing to work together
`
`to finalize a filing for the protective order, and respectfully request that this deadline be extended
`
`an additional week up to and through to October 25, 2017.
`
`Pursuant to the Court’s Discovery Order (DKT45), the deadline to file a proposed E-
`
`Discovery Order is October 20, 2017. The Parties are working together to finalize a filing for the
`
`
`
`Case 2:17-cv-00516-JRG Document 47 Filed 10/17/17 Page 2 of 3 PageID #: 389
`
`e-discovery order, and respectfully request that this deadline be extended five days up to and
`
`through to October 25, 2017.
`
`These requests are supported by good cause because the parties have been, and wish to
`
`continue discussing each side's proposals with respect to the proposed orders, with the hope of
`
`resolving disputes and narrowing the issues that may need to be presented to the Court.
`
`Dated: October 17, 2017
`
`Respectfully Submitted,
`
`/s/ Melissa R. Smith
`Melissa Richards Smith
`State Bar No. 24001351
`GILLAM & SMITH, LLP
`303 South Washington Ave.
`Marshall, TX 75670
`Tel: (903) 934-8450
`Fax: (903) 934-9257
`Email: melissa@gillamsmithlaw.com
`
`John M. Desmarais (pro hac vice pending)
`Michael P. Stadnick (pro hac vice pending)
`Ameet A. Modi (pro hac vice pending)
`Kerri-Ann Limbeek (pro hac vice pending)
`Brian Matty (pro hac vice pending)
`DESMARAIS LLP
`230 Park Avenue
`New York, NY 10169
`Tel: (212) 351-3400
`Fax: (212) 351-3401
`Email: jdesmarais@desmaraisllp.com
`Email: mstadnick@desmaraisllp.com
`Email: amodi@desmaraisllp.com
`Email: klimbeek@desmaraisllp.com
`Email: bmatty@desmaraisllp.com
`
`Attorneys for Defendant Apple Inc.
`
`/s/ Jennifer L. Truelove___________
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`
`
`
`Case 2:17-cv-00516-JRG Document 47 Filed 10/17/17 Page 3 of 3 PageID #: 390
`
`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
`Facsimile: (903) 923-9099
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@brownrudnick.com
`Alessandra C. Messing
`NY Bar No. 5040019
`Email: amessing@brownrudnick.com
`John A. Rubino
`NY Bar No. 5020797
`Email: jrubino@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: (212) 209-4800
`Facsimile: (212) 209-4801
`
`ATTORNEYS FOR PLAINTIFF,
`AGIS SOFTWARE DEVELOPMENT
`LLC
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that counsel of record who are deemed to have consented
`
`to electronic services are being served with a copy of this document via the Court’s CM/ECF
`
`system per Local Rule CV-5(a)(3) on this the 17th day of October, 2017.
`
`/s/ Melissa R. Smith
`
`
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