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`Plaintiff,
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`v.
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`VOLKSWAGEN AG,
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`Defendant.
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`NORTHSTAR SYSTEMS LLC,
`
`Plaintiff,
`
`v.
`
`BAYERISCHE MOTOREN WERKE AG,
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`Defendant.
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`
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`Case No. 2:22-cv-00486-JRG (Lead Case)
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`JURY TRIAL DEMANDED
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`
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`Case No. 2:22-cv-00496-JRG (Member Case)
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`JURY TRIAL DEMANDED
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`
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`
`)
`)
`)
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`Case 2:22-cv-00486-JRG Document 77 Filed 09/26/23 Page 1 of 3 PageID #: 953
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`DEFENDANT BAYERISCHE MOTOREN WERKE AG’S UNOPPOSED
`MOTION TO EXTEND DEFENDANT’S DEADLINE TO ANSWER OR OTHERWISE
`RESPOND TO PLAINTIFF’S AMENDED COMPLAINT
`
`Defendant Bayerische Motoren Werke AG (“BMW AG”) hereby files this Unopposed
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`Motion to Extend Defendant’s Deadline to Answer or Otherwise Respond to NorthStar’s
`
`Amended Complaint to October 18, 2023.
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`On September 19, 2023, NorthStar filed its Amended Complaint against BMW AG in
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`Lead Case 2:22-cv-00486. Dkt No. 74. The current deadline for Defendant to answer or
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`otherwise respond to the Amended Complaint is October 4, 2023.
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`The Parties have conferred on Defendant’s request for an extension of the deadline to
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`October 18, 2023, and NorthStar is not opposed to the request. Good cause exists to extend
`
`
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`Case 2:22-cv-00486-JRG Document 77 Filed 09/26/23 Page 2 of 3 PageID #: 954
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`Defendant’s deadline to respond to the Amended Complaint, so that Defendant may consider the
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`additional allegations included in the Amended Complaint.
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`WHEREFORE, Defendant respectfully requests that the Court extend their deadline to
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`answer or otherwise respond to NorthStar’s Amended Complaint to OCTOBER 18, 2023.
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`
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`Dated: September 26, 2023
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`Respectfully submitted,
`
`
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`
`
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`
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`Virginia Bar No. 49,005
`lionel.lavenue@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`1875 Explorer Street, Suite 800
`Reston, VA 20190
`Phone: (571) 203-2700
`Fax: (202) 408-4400
`
`ATTORNEY FOR DEFENDANT
`BAYERISCHE MOTOREN WERKE AG
`
`
`
`
`
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`
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`Case 2:22-cv-00486-JRG Document 77 Filed 09/26/23 Page 3 of 3 PageID #: 955
`
`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Defendant Bayerische Motoren Werke AG has met and
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`conferred with Counsel for Plaintiff to the relief requested. Plaintiff does not oppose this motion.
`
`
`
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
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` I hereby certify that on September 26, 2023, I electronically filed the foregoing
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`UNOPPOSED MOTION TO EXTEND DEFENDANT’S DEADLINE TO ANSWER OR
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`OTHERWISE RESPOND TO PLAINTIFF’S AMENDED COMPLAINT with the Clerk of
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`the Court using the CM/ECF system which will send notification of such filing via electronic
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`mail to all counsel of record.
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`
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue
`
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