`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`Case No. 5:19-cv-0036-RWS
`
`
`JURY TRIAL DEMANDED
`
`
`
`MAXELL, LTD.’S UNOPPOSED MOTION FOR EXPEDITED BRIEFING ON ITS
`OPPOSED MOTION FOR EXTENSION OF TIME TO SUPPLEMENT
`INFRINGEMENT CONTENTIONS PURSUANT TO P.R. 3-1(g)
`
`
`
`Pursuant to Local Rule CV-7(e), Plaintiff Maxell, Ltd. (“Maxell”) respectfully requests
`
`an expedited briefing schedule with respect to its Opposed Motion for Extension of Time to
`
`Supplement Infringement Contentions Pursuant to P.R. 3-1(g) (the “Motion”), which was filed
`
`with the Court on March 3, 2020. Maxell requests that any opposition brief be due on March 6,
`
`2020, with no additional briefing from the parties, and no hearing. Apple does not oppose this
`
`request.
`
`
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`Expedited briefing is appropriate in view of the fact that Maxell seeks relief from the
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`Court’s current deadline of March 13, 2020 for Maxell to supplement its infringement
`
`contentions pursuant to P.R. 3-1(g). In the absence of an expedited schedule, briefing on
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`Maxell’s Motion would not be complete prior to the March 13 deadline and an order on Maxell’s
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`Motion would have no effect. Expedited briefing is further appropriate in view of the fact that
`
`the issue presented by Maxell’s motion is very narrow.
`
`
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`Accordingly, Maxell requests that the Court order the following expedited briefing
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`schedule concerning Maxell’s Motion:
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`
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`Case 5:19-cv-00036-RWS Document 208 Filed 03/03/20 Page 2 of 5 PageID #: 8660
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`
`
`
`
`
`
`Brief
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`Defendant’s Response
`
`Maxell’s Reply
`
`Defendant’s Sur-Reply
`
`Due Date
`
`March 6, 2020
`
`None to be filed
`
`None to be filed
`
`Dated: March 3, 2020
`
`
`
`
`
`By:
`
`/s/ Jamie B. Beaber
`
`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
`
`Jamie B. Beaber
`Alan M. Grimaldi
`Kfir B. Levy
`James A. Fussell, III
`Baldine B. Paul
`Tiffany A. Miller
`Saqib Siddiqui
`Bryan 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
`
`
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 208 Filed 03/03/20 Page 3 of 5 PageID #: 8661
`
`
`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 S. 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.
`
`
`
`3
`
`
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`Case 5:19-cv-00036-RWS Document 208 Filed 03/03/20 Page 4 of 5 PageID #: 8662
`
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that Plaintiff Maxell, Ltd. has complied with the requirements of Local
`Rule CV-7(h) governing this case. Specifically, the parties held a telephonic meet and confer on
`March 3, 2020, attended by lead and local counsel for both parties. Maxell and Apple agreed
`upon the relief requested by this motion.
`
`
`
`
`
`/s/ Jamie B. Beaber
`Jamie B. Beaber
`
`
`
`/s/ Geoff Culbertson
`Geoff Culbertson
`
`
`
`
`
`
`
`
`
`
`
`
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`
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`Case 5:19-cv-00036-RWS Document 208 Filed 03/03/20 Page 5 of 5 PageID #: 8663
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 3rd day of March, 2020, with a copy of this document via
`the Court’s CM/ECF system per Local Rule CV-5(a)(3) on.
`
`
`
`
`/s/ Jamie B. Beaber
`Jamie B. Beaber
`
`
`
`
`
`
`
`
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`
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