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Case 2:22-cv-00486-JRG Document 29 Filed 06/22/23 Page 1 of 3 PageID #: 207
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`NORTHSTAR SYSTEMS LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`VOLKSWAGEN AG,
`
`
`Defendant.
`
`
`
`NORTHSTAR SYSTEMS LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`BAYERISCHE MOTOREN WERKE AG,
`
`
`Defendant.
`
`
`
`
`
`
`
`
`Case No. 2:22-cv-00486-JRG (Lead Case)
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Case No. 2:22-cv-00496-JRG (Member Case)
`
`JURY TRIAL DEMANDED
`
`UNOPPOSED MOTION FOR EXTENSION OF TIME FOR PLAINTIFF NORTHSTAR
`SYSTEMS LLC TO FILE A RESPONSE IN OPPOSITION TO DEFENDANT
`BAYERISCHE MOTOREN WERKE AG’S MOTION TO DISMISS THE COMPLAINT
`PURSUANT TO RULE 12(b)(6) AND 12(b)(7) (DKT. NO. 26)
`
`Plaintiff NorthStar Systems LLC (“NorthStar” or “Plaintiff”) hereby moves, with the
`
`Court’s permission, for extensions of time as follows:
`
`•
`
`NorthStar’s time to file its Response in Opposition to Defendant Bayerische
`
`Motoren Werke AG’s (“BMW”) Motion to Dismiss Plaintiff’s Complaint (Dkt. No.
`
`26) from July 3, 2023, up to and including July 17, 2023; and
`
`BMW does not oppose this motion. Plaintiff respectfully requests that the Court grant this
`
`Motion and does not file this Motion for purposes of delay, but rather to allow Plaintiff to
`
`

`

`Case 2:22-cv-00486-JRG Document 29 Filed 06/22/23 Page 2 of 3 PageID #: 208
`
`adequately address the complexity of the issues associated with the pending Motion and in order
`
`that justice be done.
`
`Dated: June 22, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/s/ Vincent J. Rubino, III
`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 Road, Suite 206 South
`Rye, NY 10580
`Telephone: (212) 257-5797
`Facsimile: (212) 257-5796
`
`John Andrew Rubino
`NY Bar No. 5020797
`Email: jarubino@rubinoip.com
`Michael Mondelli III
`NY Bar No. 5805114
`Email: mmondelli@rubinoip.com
`RUBINO IP
`51 J.F.K. Parkway
`Short Hills, NJ, 07079
`Telephone: (201) 341-9445
`Facsimile: (973) 535-0921
`
`Justin Kurt Truelove
`Texas Bar No. 24013653
`Email: kurt@truelovelawfirm.com
`TRUELOVE LAW FIRM, PLLC
`100 West Houston
`Marshall, Texas 75670
`Telephone: (903) 938-8321
`Facsimile: (903) 215-8510
`
`ATTORNEYS FOR PLAINTIFF
`NORTHSTAR SYSTEMS LLC
`
`
`
`
`
`
`

`

`Case 2:22-cv-00486-JRG Document 29 Filed 06/22/23 Page 3 of 3 PageID #: 209
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that, on June 22, 2023, all counsel of record who are
`
`deemed to have consented to electronic service are being served with a copy of this document via
`
`the Court’s CM/ECF system per Local Rule CV-5(a)(3).
`
`
`
`CERTIFICATE OF CONFERENCE
`
`/s/ Vincent J. Rubino, III
`Vincent J. Rubino, III
`
`
`
`The undersigned hereby certifies that all counsel of record have met and conferred in
`
`accordance with Local Rule CV-7(h) and this joint motion is agreed.
`
`/s/ Vincent J. Rubino, III
`Vincent J. Rubino, III
`
`
`
`
`
`
`
`

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