`
`
`
`
` IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`AGIS SOFTWARE DEVELOPMENT
`LLC,
`
`
`v.
`
`ZTE CORPORATION, ZTE (USA) INC.,
`AND ZTE (TX), INC.,
`
` Defendants.
`
`Plaintiff,
`
`
`
`
`
`
`
`
`Case No. 2:17-CV-00517-JRG
`
`
`
`
`
`
`UNOPPOSED MOTION TO EXTEND DEADLINE FOR DEFENDANTS’ REPLY TO
`PLAINTIFF’S RESPONSE TO MOTION TO DISMISS COMPLAINT FO FAILURE TO
`STATE A CLAIM AND IMPROPER VENUE OR IN THE ALTERNATIVE TO
`TRANSFER (D.E. 46)
`
`This Motion is unopposed. Defendants ZTE (USA) Inc. and ZTE (TX), Inc. (“ZTE”)
`
`hereby respectfully move the Court to extend the deadline for ZTE to reply to Plaintiff AGIS
`
`Software Development LLC’s (“Plaintiff”) Response to the Motion to Dismiss Plaintiff’s
`
`Complaint for Failure to State a Claim and Improper Venue or in the Alternative to Transfer (Dkt.
`
`No. 46) by 3 days, from January 19, 2018 to January 24, 2018. Further, the Parties stipulate and
`
`agree to an extension of time for Plaintiff’s Sur-Reply in support of the above-referenced
`
`Response (Dkt. No. 46) from January 30, 2018 to February 2, 2018. If approved, this extension
`
`accommodates employee schedules as well as vacation and holiday issues due to the Dr. Martin
`
`Luther King, Jr. weekend.
`
`The Defendants do not file this Unopposed Motion for the purposes of delay, but rather to
`
`allow for the complexity of the issues associated with the pending Motions, to accommodate
`
`vacation and holiday schedules, and in order that justice be done.
`
`1
`
`
`
`Case 2:17-cv-00517-JRG Document 49 Filed 01/17/18 Page 2 of 4 PageID #: 592
`
`
`
`
`
`
`
`
`Dated: January 17, 2018
`
`
`
`
`
`
`
`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, VA 20190
`Phone: (571) 203-2700
`Fax: (202) 408-4400
`
`ATTORNEY FOR DEFENDANTS
`ZTE (USA) INC. AND ZTE (TX), INC.
`
`
`
`
`
`2
`
`
`
`Case 2:17-cv-00517-JRG Document 49 Filed 01/17/18 Page 3 of 4 PageID #: 593
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that all counsel of record who are deemed to have consented to electronic
`
`service are being served this January 17, 2018, with a copy of this document via the Court’s
`
`CM/ECF system per Local Rule CV-5(a)(3).
`
`Lionel M. Lavenue
`Lionel M. Lavenue
`
`
`
`
`
`
`3
`
`
`
`Case 2:17-cv-00517-JRG Document 49 Filed 01/17/18 Page 4 of 4 PageID #: 594
`
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned attorney hereby certifies that counsel for Defendants, Lionel Lavenue,
`
`conferred with counsel for Plaintiff, Vincent Rubino, via e-mail on January 16, 2018 and there is
`
`not opposition to the relief requested in this motion.
`
`Lionel M. Lavenue
`Lionel M. Lavenue
`
`
`
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
