`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT,
`LLC,
`
` Plaintiff,
`
`
`
`
`
`
`ZTE CORPORATION AND
`ZTE (TX), INC.,
`
` Defendants.
`
`
`
`
`
`
`v.
`
`
`
`
`
`CASE NO. 2:17-cv-517
`
`
`JURY TRIAL DEMANDED
`
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME FOR
`DEFENDANT ZTE (TX), INC.
`TO ANSWER OR OTHERWISE RESPOND TO AGIS’ COMPLAINT
`
`Defendant ZTE (TX), Inc. (“ZTX”) respectfully files this unopposed motion for an
`
`extension of time to respond to Plaintiff Agis Software Development, LLC’s (“Agis”)
`
`Complaint. Currently, ZTX has until September 12, 2017, to respond to Agis’ Complaint. See
`
`Dkt. No. 23. On August 23, 2017, new counsel for ZTX entered an appearance, See Dkt. No. 22,
`
`and prior counsel for ZTX is now expected to withdraw. To allow for this change of counsel,
`
`and for new counsel to review and prepare a response to Agis’ claims against ZTX in the
`
`Complaint, ZTX seeks a fourteen (14) days extension of time to answer or otherwise respond to
`
`the complaint. Accordingly, this Motion is made for good cause, and not for delay or tactical
`
`advantage. As indicated in the above caption, Plaintiff does not oppose this Motion.
`
`
`
`
`
`
`
`Case 2:17-cv-00517-JRG Document 24 Filed 09/07/17 Page 2 of 4 PageID #: 159
`
`Respectfully submitted this 7th day of September, 2017
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Lionel M. Lavenue
`
`Lionel M. Lavenue - Lead Counsel
`Virginia Bar No. 49005
`lionel.lavenue@finnegan.com
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, L.L.P.
`Two Freedom Square
`11955 Freedom Dr.
`Reston, VA 20105
`(571) 203-2700 (telephone)
`(202) 408-4400 (facsimile)
`
`COUNSEL FOR DEFENDANT
`ZTE (TX), INC.
`
`
`
`
`
`2
`
`
`
`Case 2:17-cv-00517-JRG Document 24 Filed 09/07/17 Page 3 of 4 PageID #: 160
`
`CERTIFICATE OF CONFERENCE
`
`The Parties have complied with Local Rule CV-7(h). Communications were exchanged
`
`between Lionel M. Lavenue for ZTE (TX), Inc. and Vincent Rubino for Agis on
`
`September 7, 2017. Agis’ counsel confirmed that it does not oppose this motion.
`
`
`
`
`
` /s/ Lionel M. Lavenue
`Lionel M. Lavenue
`
`
`
`
`
`3
`
`
`
`Case 2:17-cv-00517-JRG Document 24 Filed 09/07/17 Page 4 of 4 PageID #: 161
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that, on September 7, 2017, the foregoing document was served upon
`
`counsel of record who are deemed to have consented to electronic service via the Court’s
`
`CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
` /s/ Lionel M. Lavenue
`Lionel M. Lavenue
`
`
`
`
`
`4
`
`
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