`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`MAXELL, LTD.’S UNOPPOSED MOTION FOR LEAVE TO EXCEED
`PAGE LIMIT FOR ATTACHMENTS TO ITS OPPOSITION TO APPLE INC.’S
`MOTION TO COMPEL INFRINGEMENT CONTENTIONS COMPLIANT
`WITH PATENT RULE 3-1(G) OR, IN THE ALTERNATIVE,
`TO PRECLUDE MAXELL’S RELIANCE ON SOURCE CODE FOR INFRINGEMENT
`
`Maxell seeks leave to exceed the page limitation for attachments contained in the Court’s June 3,
`
`
`
`
`2016 Standing Order Regarding “Meet and Confer” Obligations Relating to Discovery Disputes. Given
`
`Apple’s characterizations and accusations of Maxell’s contentions, Maxell seeks leave to provide a full
`
`set of its Supplemental Infringement Contentions for the Court’s in camera review.
`
`Apple does not oppose this relief.
`
`Respectfully submitted,
`
`Dated: November 27, 2019
`
`By:
`
`/s/ Geoff Culbertson
`
`Geoff Culbertson
`Kelly Tidwell
`PATTON, TIDWELL & CULBERTSON, LLP
`2800 Texas Boulevard (75503)
`Post Office Box 5398
`Texarkana, TX 75505-5398
`Telephone: (903) 792-7080
`Facsimile: (903) 792-8233
`gpc@texarkanalaw.com
`kbt@texarkanalaw.com
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 143 Filed 11/27/19 Page 2 of 3 PageID #: 5975
`
`
`
`
`
`
`Jamie B. Beaber
`Alan M. Grimaldi
`Kfir B. Levy
`James A. Fussell, III
`Baldine B. Paul
`Tiffany A. Miller
`Saqib J. Siddiqui
`Bryan C. Nese
`William J. Barrow
`Alison T. Gelsleichter
`Clark S. Bakewell
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`agrimaldi@mayerbrown.com
`klevy@mayerbrown.com
`jfussell@mayerbrown.com
`bpaul@mayerbrown.com
`tmiller@mayerbrown.com
`ssiddiqui@mayerbrown.com
`bnese@mayerbrown.com
`wbarrow@mayerbrown.com
`agelsleichter@mayerbrown.com
`cbakewell@mayerbrown.com
`
`Robert G. Pluta
`Amanda Streff Bonner
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 782-0600
`rpluta@mayerbrown.com
`asbonner@mayerbrown.com
`
`Counsel for Plaintiff Maxell, Ltd.
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 143 Filed 11/27/19 Page 3 of 3 PageID #: 5976
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 27th day of November, 2019, with a copy of this
`document via the Court’s electronic CM/ECF system.
`
`
`
`
`/s/ Geoff Culbertson
`Geoff Culbertson
`
`
`
`
`
`
`
`
`
`
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`3
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