`158
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`BYTEWEAVR, LLC
`
`
`Plaintiff,
`
`
`
`v.
`
`
`DATABRICKS, INC.,
`
`
`Defendants.
`
`
`
`
`
`
`Civil Action No. 2:24-cv-00162-JRG-RSP
`
` JURY TRIAL DEMANDED
`
`JOINT MOTION FOR EXTENSION OF TIME TO FILE PROTECTIVE ORDER
`
`Plaintiff Byteweavr, LLC (“Byteweavr”) and Defendant Databricks, Inc. (“Databricks”)
`
`respectfully submit this Unopposed Motion to extend the deadline for filing a Protective Order.
`
`The current deadline for the Parties to submit a Protective Order is June 20, 2024 (Dkt. No.
`
`11).1 The Parties respectfully request a one-week extension of the current deadline, up to and
`
`including June 27, 2024.
`
`Good cause exists for extending the deadline. The parties are coordinating efforts and
`
`diligently working toward reaching a resolution on outstanding disputes. In order to resolve any
`
`outstanding disputes and minimize issues that need to be presented to the Court, the Parties
`
`respectfully request an additional week to submit the Protective Order to the Court.
`
`Accordingly, the Parties respectfully request that the Unopposed Motion be granted, and
`
`that the deadline to file the Protective Order be extended from June 20, 2024, up to and including
`
`June 27, 2024.
`
`
`1 The Court order setting a scheduling conference (Dkt. 11) set a deadline of 3 weeks after
`the scheduling conference of May 29, 2024 (which was June 19, 2024, a federal holiday). Under
`Fed. R. Civ. P. 6(a)(1)(C), the deadline is June 20, 2024.
`
`
`
`1
`
`
`
`Case 2:24-cv-00162-JRG-RSP Document 23 Filed 06/20/24 Page 2 of 3 PageID #:
`159
`
`
`
`Dated: June 20, 2024
`
`
`
`
`
`/s/ Terry A. Saad
`Jeffrey R. Bragalone
`State Bar No. 02855775
`Email: jbragalone@bosfirm.com
`Terry A. Saad
`State Bar No. 24066015
`Email: tsaad@bosfirm.com
`Marcus Benavides
`State Bar No. 24035574
`Brandon V. Zuniga
`State Bar No. 24088720
`Email: bzuniga@bosfirm.com
`Mark M.R. Douglass
`State Bar No. 24131184
`Email: mdouglass@bosfirm.com
`BRAGALONE OLEJKO SAAD PC
`901 Main Street, Suite 3800
`Dallas, Texas 75202
`Telephone: (214) 785-6670
`Facsimile: (214) 785-6680
`
`Attorneys for Plaintiff Byteweavr, LLC
`
`
`
`/s/ Jessica M. Kaempf
`Michael J. Sacksteder
`CA Bar No. 191605 (Admitted E.D. Texas)
`Email: msacksteder@fenwick.com
`Gregory Sefian
`CA Bar No. 341802 (Admitted Pro Hac Vice)
`Email: gsefian@fenwick.com
`Su Li
`CA Bar No. 339374 (Admitted Pro Hac Vice)
`Email: sli@fenwick.com
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, California 94104
`Telephone:
`415.875.2300
`Facsimile:
`415.281.1350
`
`Vigen Salmastlian
`CA Bar No. 276846 (Admitted E.D. Texas)
`Email: vsalmastlian@fenwick.com
`FENWICK & WEST LLP
`801 California Street,
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Jonathan G. Tamimi
`WA Bar No. 54858 (Admitted E.D. Texas)
`Email: jtamimi@fenwick.com
`Jessica M. Kaempf
`WA Bar No. 51666 (Admitted E.D. Texas)
`Email: jkaempf@fenwick.com
`FENWICK & WEST LLP
`401 Union Street, 5th Floor
`Seattle, WA 98101
`Telephone:
`206.389.4510
`Facsimile:
`206.389.4511
`
`Attorneys for Defendant Databricks, Inc.
`
`
`
`
`
`
`
`2
`
`
`
`Case 2:24-cv-00162-JRG-RSP Document 23 Filed 06/20/24 Page 3 of 3 PageID #:
`160
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that all counsel of record who consented to electronic service are being
`
`served with a copy of this document via electronic mail per Local Rule CV-5 on June 20, 2024.
`
`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
`
`
`
`
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that counsel for Defendant has complied with L.R. 7(h)
`
`regarding this motion. Counsel for Defendant met and conferred with counsel for Plaintiff via
`
`telephone, and counsel for Plaintiff indicated that it does not oppose the relief requested by this
`
`motion.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Jessica M. Kaempf
`Jessica M. Kaempf
`
`
`
`3
`
`

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