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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`§
`Case No. 2:22-cv-00263-JRG-RSP
`§
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`§
`JURY TRIAL DEMANDED
`§
`§
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`§
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`§
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`§
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`JOINT MOTION FOR ENTRY
`OF AGREED DOCKET CONTROL ORDER
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`Pursuant to the Court’s Order Setting the Scheduling Conference dated October 19, 2022
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`v.
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`SAMSUNG ELECTRONICS CO., LTD.,
`ET AL.,
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`Defendants.
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`(Dkt. 15), Plaintiff AGIS Software Development LLC (“Plaintiff” or “AGIS”) and Defendants
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`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, “Defendants”
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`or “Samsung”) have met and conferred and hereby file this Joint Motion for Entry of Agreed
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`Docket Control Order, attached hereto as Exhibit A.
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`The parties respectfully submit that good cause exists to modify the dates supplied by the
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`Court for filing Dispositive Motions and Motions to Strike Expert Testimony which otherwise
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`would fall on Monday, November 27, 2023. In view of the Thanksgiving holiday the preceding
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`Thursday, the Parties request to move this date to November 30, 2023 and to correspondingly
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`move the date to file Responses to Dispositive Motions (including Daubert Motions) from
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`December 11, 2023 to December 14, 2023. There is good cause for these changes because they
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`will avoid interruption of the Thanksgiving holiday without materially changing the case schedule
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`affecting any hearing dates.
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`Case 2:22-cv-00263-JRG-RSP Document 25 Filed 12/01/22 Page 2 of 4 PageID #: 629
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`Dated: December 1, 2022
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`Respectfully submitted,
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`/s/ Alfred R. Fabricant
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: ffabricant@fabricantllp.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@fabricantllp.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@fabricantllp.com
`FABRICANT LLP
`411 Theodore Fremd Avenue,
`Suite 206 South
`Rye, New York 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
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`ATTORNEYS FOR PLAINTIFF AGIS
`SOFTWARE DEVELOPMENT LLC
`
`
` /s/ Neil P. Sirota (with permission)
`Neil P. Sirota
`neil.sirota@bakerbotts.com
`Margaret M. Welsh
`margaret.welsh@bakerbotts.com
`BAKER BOTTS L.L.P.
`30 Rockefeller Plaza
`New York, NY 10112-4498
`Telephone: (212) 408-2500
`Facsimile: (212) 408-2501
`
`2
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`Case 2:22-cv-00263-JRG-RSP Document 25 Filed 12/01/22 Page 3 of 4 PageID #: 630
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`
`
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`Tom Gorham
`State Bar No. 24012715
`tom@gillamsmithlaw.com
`Melissa R. Smith
`State Bar No. 24001351
`melissa@gillamsmithlaw.com
`GILLAM & SMITH LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`ATTORNEYS FOR DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
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`3
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`Case 2:22-cv-00263-JRG-RSP Document 25 Filed 12/01/22 Page 4 of 4 PageID #: 631
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, on December 1, 2022, all counsel of record who are
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`deemed to have consented to electronic service are being served with a copy of this document via
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`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
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`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that counsel for Plaintiff has met and conferred with
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`counsel for Defendants, and all parties have agreed to the proposed order submitted herewith.
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`/s/ Alfred R. Fabricant
` Alfred R. Fabricant
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