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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Case No. 2:22-cv-0185-JRG
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`v.
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`VERIZON COMMUNICATIONS INC. and
`CELLCO PARTNERSHIP, d/b/a VERIZON
`WIRELESS,
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`Defendants.
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`COMPLY WITH P.R. 3-3 AND 3-4
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`Defendants file this Unopposed Motion for Extension of Time to comply with P.R. 3-3 and
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`3-4(b), and shows the Court as follows: Defendants’ counsel has been working diligently over the
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`past several weeks and needs one additional week to gather documents and draft invalidity
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`contentions and subject-matter eligibility contentions.
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` The current deadline to comply with P.R. 3-3 and 3-4 is December 5, 2022 and Defendants
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`have requested, and AGIS has agreed to a one-week extension of this deadline to comply with P.R.
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`3-3 and 3-4(b) and to comply with the Standing Order Regarding Subject-Matter Eligibility
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`Contentions. The new deadlines would be December 12, 2022.
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`Original Dates
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`Amended Dates
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`Event
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`December 5, 2022 December 12, 2022 Comply with Standing Order Regarding Subject-
`Matter Eligibility Contentions
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`December 5, 2022 December 12, 2022 Comply with P.R. 3-3 (Invalidity Contentions) and
`P.R. 3-4(b)
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`DM2\16943058.1
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`Case 2:22-cv-00185-JRG Document 45 Filed 12/02/22 Page 2 of 4 PageID #: 637
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`Wherefore, Defendants respectfully request that the Court extend the deadlines for
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`Defendants to comply with P.R. 3-3 and 3-4(b) and to comply with the Standing Order Regarding
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`Subject-Matter Eligibility Contentions up to and including December 12, 2022. The Parties are not
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`proposing to change any other deadlines and stipulate to the Proposed Second Amended Docket
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`Control Order, which is attached hereto.
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`DM2\16943058.1
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`2
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`Case 2:22-cv-00185-JRG Document 45 Filed 12/02/22 Page 3 of 4 PageID #: 638
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`Dated: December 2, 2022
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`
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`Respectfully submitted,
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`By: /s/ Holly Engelmann
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`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
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`Attorneys for Defendants
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`DM2\16943058.1
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`3
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`Case 2:22-cv-00185-JRG Document 45 Filed 12/02/22 Page 4 of 4 PageID #: 639
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that the foregoing document was filed electronically in
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`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 December 2, 2022.
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`/s/ Holly Engelmann
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`CERTIFICATE OF CONFERENCE
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`Counsel for Defendants conferred with Counsel for Plaintiff and counsel for Plaintiff
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`confirmed that Plaintiff does not oppose the relief requested in this motion.
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`/s/ Holly Engelmann
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`DM2\16943058.1
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`4
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