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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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` Civil Action No. 2:19-cv-00209
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`JURY TRIAL DEMANDED
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`THE HILLMAN GROUP, INC.,
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`KEYME, INC.,
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`Plaintiff,
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`v.
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`Defendant.
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`AGREED JOINT MOTION FOR LIMITED VENUE DISCOVERY
`AND EXTENSION OF BRIEFING DEADLINES
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`This agreed Joint Motion is made by and between Plaintiff The Hillman Group, Inc.
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`(“Hillman”) and Defendant KeyMe, LLC (“KeyMe”):
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`WHEREAS, Hillman filed the Complaint in this Action (D.I. 1) on June 3, 2019;
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`WHEREAS, KeyMe filed a Sealed Motion to Dismiss for Improper Venue or, in the
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`Alternative, to Transfer to the Southern District of New York (D.I. 12/13/16), as well as a Motion
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`to Transfer Venue to the Southern District of New York Under 28 U.S.C. § 1404 (D.I. 14)
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`(collectively, “KeyMe’s Motions”) on July 25, 2019;
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`WHEREAS, Hillman’s deadline to respond to KeyMe’s Motions is presently August 8,
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`2019;
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`WHEREAS, Hillman and KeyMe each seek to serve interrogatories, requests for
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`production, and one (1) Rule 30(b)(6) deposition notice containing approximately 5 topics (the
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`“Venue Discovery”) targeted to the venue issues; and
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`Case 2:19-cv-00209-JRG Document 20 Filed 08/05/19 Page 2 of 3 PageID #: 530
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`WHEREAS, the parties seek to minimize the burden on the Court and ensure the just,
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`speedy, and inexpensive determination of their present dispute;
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`NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between
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`the parties, by and through their undersigned counsel, and subject to approval of the Court, that:
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`1. Hillman may serve 5 interrogatories and 5 requests for production for the purposes of
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`Venue Discovery;
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`2. KeyMe may serve 3 interrogatories and 3 requests for production for the purposes of
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`Venue Discovery;
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`3. Hillman and KeyMe will serve the Venue Discovery on the other party within three (3)
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`calendar days of the filing of this agreed Joint Motion;
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`4. The parties will serve responses and responsive documents and things to the Venue
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`Discovery on the other party within twenty (20) calendar days of being served with the
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`Venue Discovery;
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`5. The Rule 30(b)(6) depositions will be held within fourteen (14) calendar days of the
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`service of the respective responses and responsive documents at a mutually agreeable
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`location, for a maximum of four (4) hours each; and
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`6. Hillman’s Oppositions to KeyMe’s Motions will be due fourteen (14) calendar days
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`after the date of the last of the Rule 30(b)(6) depositions.
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`Dated: August 5, 2019
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`_/s/Eric H. Findlay_________________
`Eric H. Findlay (Bar No. 00789886)
`FINDLAY CRAFT, P.C.
`102 North College Avenue, Suite 900
`Tyler, TX 75702
`(903) 534-1100
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`/s/Deron R. Dacus
`Deron R. Dacus (Bar No. 00790553)
`THE DACUS FIRM, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
`(903) 705-1177
`2
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`Case 2:19-cv-00209-JRG Document 20 Filed 08/05/19 Page 3 of 3 PageID #: 531
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`(903) 534-1137 (fax)
`efindlay@findlaycraft.com
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`Of Counsel:
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`Christopher P. Isaac
`Ryan P. O’Quinn
`FINNEGAN, HENDERSON, FARABOW,
` GARRETT & DUNNER, L.L.P.
`11955 Freedom Drive
`Reston, VA 20190
`(571) 203-2700
`(202) 208-4400 (fax)
`chris.isaac@finnegan.com
`oquinnr@finnegan.com
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`Attorneys for Plaintiff
`The Hillman Group, Inc.
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`(903) 581-2543 (fax)
`ddacus@dacusfirm.com
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`Of Counsel:
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`Michael G. Rhodes
`COOLEY L.L.P.
`101 California Street, 5th Floor
`San Francisco, CA 94111
`(415) 693-2000
`(415) 693-2222 (fax)
`rhodesmg@cooley.com
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`Stephen R. Smith
`Rose S. Whelan
`COOLEY L.L.P.
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`(202) 842-7800
`(202) 842-7899 (fax)
`stephen.smith@cooley.com
`rwhelan@cooley.com
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`Attorneys for Defendant KeyMe, LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that on August 5, 2019, I electronically filed the foregoing document with
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`the Clerk of the Court using the CM/ECF system. This document will be served on all counsel of
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`record in accordance with the Federal Rules of Civil Procedure.
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`/s/ Eric H. Findlay
`Eric H. Findlay
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