`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`
`
`Plaintiff,
`
`
`v.
`
`UBER TECHNOLOGIES INC.,
`d/b/a UBER,
`
`
`
`Defendant.
`
`
`
`Case No. 2:21-cv-00026-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`DEFENDANT’S UNOPPOSED MOTION FOR ENTRY OF AMENDED DEADLINE TO
`ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT
`
`Defendant Uber Technologies Inc. (“Uber”) respectfully requests that the Court grant its
`
`Unopposed Motion for Entry of Amended Deadline to Answer or Otherwise Respond to
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`Plaintiff’s Complaint (Dkt. No. 1). Though Plaintiff AGIS Software Development LLC
`
`(“AGIS”) filed an executed summons on February 15, 2021 (Dkt. No. 9), the summons was
`
`served on an incorrect entity. Rather than require AGIS to re-serve the summons, which may
`
`result in delay, Uber has agreed to waive service of a summons in exchange for a deadline to
`
`answer or otherwise respond of April 23, 2021. This motion is being made for good cause and
`
`not for the purpose of delay. Accordingly, Uber respectfully requests that its deadline to answer
`
`or otherwise respond be set as April 23, 2021. Uber has met and conferred with counsel for
`
`AGIS, who does not oppose this motion.
`
`
`
`
`
`
`
`Case 2:21-cv-00026-JRG-RSP Document 14 Filed 02/22/21 Page 2 of 4 PageID #: 186
`
`Respectfully submitted,
`
`GIBSON, DUNN & CRUTCHER LLP
`
`By:
`/s/ Mark N. Reiter
`Mark N. Reiter
`Texas State Bar No. 16759900
`mreiter@gibsondunn.com
`Robert A. Vincent
`Texas State Bar No. 24056474
`rvincent@gibsondunn.com
`Nathan R. Curtis
`Texas State Bar No. 24078390
`ncurtis@gibsondunn.com
`Ashbey N. Morgan
`Texas State Bar No. 24106339
`anmorgan@gibsondunn.com
`GIBSON, DUNN & CRUTCHER LLP
`2001 Ross Avenue, Suite 2100
`Dallas, Texas 75201
`Telephone: (214) 698-3100
`Facsimile: (214) 571-2900
`
`ATTORNEYS FOR DEFENDANT
`UBER TECHNOLOGIES INC. d/b/a UBER
`
`
`
`
`
`Case 2:21-cv-00026-JRG-RSP Document 14 Filed 02/22/21 Page 3 of 4 PageID #: 187
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that on February 22, 2021, Defendant conferred with attorney for AGIS,
`
`who agreed to the extension and did not oppose this Motion.
`
`
`
`/s/ Mark N. Reiter
`Mark N. Reiter
`
`
`
`
`
`
`
`
`
`Case 2:21-cv-00026-JRG-RSP Document 14 Filed 02/22/21 Page 4 of 4 PageID #: 188
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on February 22, 2021, the foregoing was electronically filed with the
`
`Clerk of the Court using the CM/ECF system, which will send a notice of electronic filing to
`
`CM/ECF participants in this case.
`
`
`
`
`
`/s/ Mark N. Reiter
`Mark N. Reiter
`
`
`
`
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