`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`Civil Action No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`JOINT MOTION TO EXTEND PAGE LIMITS RELATED TO APPLE INC.’S
`AMENDED MOTION TO TRANSFER VENUE
`
`
`Pursuant to Local Rule 7(a)(2), Plaintiff Maxell, Ltd. (“Maxell”) and Defendant Apple
`
`Inc. (“Apple”) (collectively, the “Parties”), by and through their undersigned counsel, jointly
`
`submit this Stipulation and Proposed Order regarding the page limits applicable to the Parties’
`
`briefing in response to Apple’s Amended Motion To Transfer Venue Pursuant to 28 U.S.C. §
`
`1404(a). D.I. 57.1
`
`Maxell needs additional pages for its opposition to fully address the issues raised in
`
`Apple’s Amended Motion to Transfer Venue, and Apple needs a commensurate number of
`
`additional pages for its reply to address issues raised by Maxell in its extended brief. The Parties
`
`met and conferred, and with the goal of streamlining the motion to transfer process and
`
`conserving the Court’s judicial resources, reached the following stipulation regarding the length
`
`of any memoranda submitted in response to Apple’s Amended Motion To Transfer Venue.
`
`
`1 The Parties respectfully submit that Apple’s Motion to Transfer Venue (Dkt. No. 52) filed on
`July 31, 2019 is moot in light of the Amended Motion to Transfer Venue (Dkt. No. 57) filed on
`August 9, 2019.
`
`
`
`Case 5:19-cv-00036-RWS Document 60 Filed 08/16/19 Page 2 of 3 PageID #: 1766
`
`NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between
`
`the Parties, that:
`
`1. Maxell may file an opposition brief of no more than 25 pages, exclusive of any exhibits,
`
`in opposition to Apple’s Amended Motion To Transfer Venue.
`
`2. Apple may file a reply brief of no more than 10 pages, exclusive of any exhibits, in
`
`support of its Amended Motion To Transfer Venue.
`
`3. Each Party reserves and does not waive all other rights.
`
`Dated: August 16, 2019
`
`
`
`
`
`
`
`
`/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
`
`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
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`agrimaldi@mayerbrown.com
`
`
`
`
`/s/ Luann L. Simmons
`
`Luann L. Simmons (Pro Hac Vice)
`lsimmons@omm.com
`O’MELVENY & MYERS LLP
`Two Embarcadero Center
`28th Floor
`San Francisco, CA 94111
`Telephone: 415-984-8700
`Facsimile: 415-984-8701
`
`Xin-Yi Zhou (Pro Hac Vice)
`vzhou@omm.com
`Anthony G. Beasley (TX #24093882)
`tbeasley@omm.com
`O’MELVENY & MYERS LLP
`400 S. Hope Street
`Los Angeles, CA 90071
`Telephone: 213-430-6000
`Facsimile: 213-430-6407
`
`Laura Bayne Gore (Pro Hac Vice)
`lbayne@omm.com
`O’MELVENY & MYERS LLP
`Times Square Tower, 7 Times Square
`New York, NY 10036
`Telephone: 212-326-2000
`Facsimile: 212-326-2061
`
`
`
`
`Case 5:19-cv-00036-RWS Document 60 Filed 08/16/19 Page 3 of 3 PageID #: 1767
`
`Melissa R. Smith (TX #24001351)
`melissa@gilliamsmithlaw.com
`GILLIAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`Attorneys for Defendant Apple Inc.
`
`
`
`
`klevy@mayerbrown.com
`jfussell@mayerbrown.com
`bpaul@mayerbrown.com
`tmiller@mayerbrown.com
`
`ssiddiqui@mayerbrown.com
`bnese@mayerbrown.com
`wbarrow@mayerbrown.com
`agelsleichter@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.
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 16th day of August, 2019, with a copy of this document
`via electronic mail pursuant to Local Rule CV-5(d).
`
`
`/s/ Geoff Culbertson
`Geoff Culbertson
`
`
`
`
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