`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`Case No. 2:22-cv-0185-JRG
`
`JURY TRIAL DEMANDED
`
`Plaintiff,
`
`
`
`v.
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`
`
`
`VERIZON COMMUNICATIONS INC. and
`CELLCO PARTNERSHIP, d/b/a VERIZON
`WIRELESS,
`
`
`
`
`
`Defendants.
`
`
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO
`FIRST AMENDED COMPLAINT
`
`Defendants file this Unopposed Motion for Extension of Time to File a Response to
`
`Plaintiff AGIS Software Development LLC’s (“AGIS”)’s First Amended Complaint, and shows
`
`the Court as follows:
`
`Defendants filed a Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) (Dkt. No. 19)
`
`regarding AGIS’ Original Complaint on August 9, 2022.
`
`AGIS filed a First Amended Complaint on August 23, 2022.
`
`The current deadline to file an answer to AGIS’ First Amended Complaint is September 7,
`
`2022, and Defendants have requested, and AGIS has agreed to, a one--week extension of this
`
`deadline up to and including September 14, 2022.
`
`Wherefore, Defendants respectfully request that the Court extend the deadline for
`
`Defendants to respond to the First Amended Complaint up to and including September 14, 2022.
`
`
`
`
`
`DM2\16310770.1
`
`
`
`Case 2:22-cv-00185-JRG Document 25 Filed 08/31/22 Page 2 of 3 PageID #: 469
`
`Dated: August 31, 2022
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /s/ Deron Dacus
`
`Deron Dacus
`ddacus@dacusfirm.com
`THE DACUS FIRM, PC
`821 EDE Loop 323, Suite 430
`Tyler, TX 75701
`Tel:
`903-705-1117
`Fax: 903-581-2543
`
`Holly Engelmann
`TX Bar No. 24040865
`HEngelmann@duanemorris.com
`DUANE MORRIS LLP
`100 Crescent Court, Suite 1200
`Dallas, TX 75201
`Tel:
`214-257-7200
`Fax: 214-257-7201
`
`Kevin P. Anderson
`KPAnderson@duanemorris.com
`DUANE MORRIS LLP
`595 9th Street, N.W., Suite 1000
`Washington, DC 20004-2166
`Tel:
`202-776-5213
`Fax: 202-315-3169
`
`Attorneys for Defendants
`
`
`
`
`
`DM2\16310770.1
`
`2
`
`
`
`Case 2:22-cv-00185-JRG Document 25 Filed 08/31/22 Page 3 of 3 PageID #: 470
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that the foregoing document was filed electronically in
`
`compliance with Local Rule CV-5(a). Plaintiff’s counsel of record was served with a true and
`
`correct copy of the foregoing document by the CM/ECF system on August 31, 2022.
`
`/s/ Deron Dacus
`
`
`
`
`
`CERTIFICATE OF CONFERENCE
`
`Counsel for Defendants conferred with Counsel for Plaintiff and counsel for Plaintiff
`
`
`
`
`
`confirmed that Plaintiff does not oppose the relief requested in this motion.
`
`
`
`
`
`/s/ Deron Dacus
`
`
`
`
`
`
`DM2\16310770.1
`
`3
`
`
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