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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`C.A. No.: 6:12-cv-00799-LED
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`JURY TRIAL DEMANDED
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`INVENSYS SYSTEMS, INC.,
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`v.
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`Plaintiff,
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`EMERSON ELECTRIC CO. and
`MICRO MOTION INC., USA,
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`Defendants.
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`PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME
`TO FILE RESPONSE TO DEFENDANT MICRO MOTION, INC.’S
`MOTION TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a)
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`Plaintiff Invensys Systems, Inc. (“Invensys”) respectfully requests a two-week extension
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`until February 11, 2013, to file its response to Defendant Micro Motion, Inc.’s (“Micro Motion”)
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`Motion to Transfer Venue Pursuant to 28 U.S.C. § 1404(a) (ECF No. 14). This request is made
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`due to (among other things) international travel by Invensys’s in-house counsel for an extended
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`period. This request for an extension is not sought for purposes of delay and will not affect any
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`other case deadlines. Counsel for Invensys has conferred with counsel for Micro Motion
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`regarding the relief requested in this motion, and Micro Motion is not opposed to Invensys’s
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`requested extension.
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`Accordingly, Invensys respectfully requests that the Court extend the date for Invensys to
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`file its response to Micro Motion’s Motion to Transfer Venue until February 11, 2013.
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`
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`Case 6:12-cv-00799-JRG Document 17 Filed 01/24/13 Page 2 of 3 PageID #: 452
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`Date:
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`January 24, 2013
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`Respectfully submitted,
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`/s/ Claudia Wilson Frost
`Claudia Wilson Frost
`State Bar No. 21671300
`Jeffrey L. Johnson
`State Bar No. 24029638
`Amy P. Mohan
`State Bar No. 24051070
`DLA PIPER LLP
`1000 Louisiana, Suite 2800
`Houston, TX 77002
`Telephone: 713.425.8400
`Facsimile: 713.425.8401
`Claudia.Frost@dlapiper.com
`Jeffrey.Johnson@dlapiper.com
`Amy.Mohan@dlapiper.com
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`ATTORNEYS FOR PLAINTIFF, INVENSYS
`SYSTEMS, INC.
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`OF COUNSEL:
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`Nicholas G. Papastavros
`Daniel Rosenfeld
`DLA PIPER LLP
`33 Arch Street, 26th Floor
`Boston, MA 02110
`Telephone: 617.406.6000
`Facsimile: 617.406.6100
`Nick.Papastavros@dlapiper.com
`Daniel.Rosenfeld@dlapiper.com
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`ATTORNEYS FOR PLAINTIFF,
`INVENSYS SYSTEMS, INC.
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that we have conferred with opposing counsel for Defendant Micro
`Motion, Inc., and they are not opposed to the relief requested in this motion.
`
`/s/ Claudia Wilson Frost
`Claudia Wilson Frost
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`EAST\54801288.1
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`2
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`Case 6:12-cv-00799-JRG Document 17 Filed 01/24/13 Page 3 of 3 PageID #: 453
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing document was filed electronically on January 24, 2013,
`pursuant to Local Rule CV-5(a) and has been served on all counsel who have consented to
`electronic service. Any other counsel of record will be served by first class U.S. mail on this
`same date.
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`/s/ Claudia Wilson Frost
`Claudia Wilson Frost
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`EAST\54801288.1
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`3