Case 4:23-cv-01147-ALM Document 24 Filed 05/30/24 Page 1 of 2 PageID #: 622
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`Civil Action No. 4:23-cv-01147-ALM
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`Jury Trial Demanded
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`Databricks, Inc.,
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` Defendant.
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`UNOPPOSED MOTION FOR EXTENSION OF TIME
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`Plaintiff R2 Solutions LLC respectfully moves the Court for a short extension of the
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`deadline to respond to Defendant Databricks, Inc.’s Motion to Transfer (ECF 20). The motion
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`was filed on Tuesday, May 21, 2024, with service of the motion occurring on Wednesday, May
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`22, 2024 per Local Rule CV-5(a)(3)(C). The deadline to respond is, thus, Wednesday, June 5,
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`2024. R2 requests an extension of the deadline by five (5) days, and agrees it will not use the
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`additional time to argue that transfer is unjustified. Databricks does not oppose. Granting this
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`motion extends the applicable deadline to Monday, June 10, 2024 and will not require
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`modification of any other date or deadline. For these reasons, R2 asks that the Court grant this
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`motion and enter the accompanying Order, accordingly.
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`Dated: May 30, 2024
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`Respectfully submitted,
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`/s/ Edward R. Nelson III
`EDWARD R. NELSON III
`State Bar No. 00797142
`ed@nelbum.com
`BRENT N. BUMGARDNER
`State Bar No. 00795272
`brent@nelbum.com
`CHRISTOPHER G. GRANAGHAN
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`Case 4:23-cv-01147-ALM Document 24 Filed 05/30/24 Page 2 of 2 PageID #: 623
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`State Bar No. 24078585
`chris@nelbum.com
`JOHN P. MURPHY
`State Bar No. 24056024
`murphy@nelbum.com
`CARDER W. BROOKS
`State Bar No. 24105536
`carder@nelbum.com
`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111
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`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that a copy of the foregoing document was filed electronically in
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`compliance with Local Rule CV-5(a). Therefore, this document was served on all counsel on May
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`30, 2024.
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`/s/ Edward R. Nelson III
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Plaintiff and counsel for Defendant conferred regarding
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`the relief sought by this motion and that this motion is unopposed.
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`/s/ Edward R. Nelson III
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`2
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