`
`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
`COMPLY WITH P.R. 3-3 AND 3-4
`
`Defendants file this Unopposed Motion for Extension of Time to comply with P.R. 3-3 and
`
`3-4, and shows the Court as follows: Defendants’ counsel has had some family-related issues over
`
`the past several weeks and need additional time to gather documents and draft invalidity
`
`contentions and subject-matter eligibility contentions.
`
` The current deadline to comply with P.R. 3-3 and 3-4 is November 7, 2022 and Defendants
`
`have requested, and AGIS has agreed to: (1) a two-week extension of this deadline to comply with
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`P.R. 3-4(a), and (2) a four-week extension of this deadline to comply with P.R. 3-3 and 3-4(b) and
`
`to comply with the Standing Order Regarding Subject-Matter Eligibility Contentions. The new
`
`deadlines would be November 21, 2022 and December 5, 2022 respectively.
`
`Original Dates
`
`Amended Dates
`
`Event
`
`November 7, 2022 December 5, 2022
`
`November 7, 2022 December 5, 2022
`
`Comply with Standing Order Regarding Subject-
`Matter Eligibility Contentions
`
`Comply with P.R. 3-3 (Invalidity Contentions) and
`P.R. 3-4(b)
`
`DM2\16766845.1
`
`
`
`Case 2:22-cv-00185-JRG Document 43 Filed 11/03/22 Page 2 of 4 PageID #: 620
`
`Original Dates
`
`Amended Dates
`
`Event
`
`November 7, 2022 November 21, 2022 Comply with P.R. 3-4(a)
`
`Wherefore, Defendants respectfully request that the Court extend (1) the deadline for
`
`Defendants to comply with P.R. 3-4(a) up to and including November 21, 2022 and (2) the
`
`deadlines for Defendants to comply with P.R. 3-3 and 3-4(b) and to comply with the Standing
`
`Order Regarding Subject-Matter Eligibility Contentions up to and including December 5, 2022.
`
`The Parties are not proposing to change any other deadlines and stipulate to the Proposed First
`
`Amended Docket Control Order, which is attached hereto.
`
`
`
`
`
`
`DM2\16766845.1
`
`2
`
`
`
`Case 2:22-cv-00185-JRG Document 43 Filed 11/03/22 Page 3 of 4 PageID #: 621
`
`Dated: November 3, 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\16766845.1
`
`3
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`
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`Case 2:22-cv-00185-JRG Document 43 Filed 11/03/22 Page 4 of 4 PageID #: 622
`
`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
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`correct copy of the foregoing document by the CM/ECF system on November 3, 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\16766845.1
`
`4
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`
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