`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`C.A. No. 6:12-cv-799-LED
`
`JURY TRIAL DEMANDED
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`§§
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`INVENSYS SYSTEMS, INC.,
`
`v.
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`Plaintiff,
`
`EMERSON ELECTRIC CO. and
`MICRO MOTION INC., USA,
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`Defendants.
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`PLAINTIFF INVENSYS SYSTEMS, INC.’S
`UNOPPOSED MOTION TO BRIEFLY DEFER CERTAIN DEADLINES
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`Plaintiff Invensys Systems, Inc. (“Invensys”), by and through the undersigned counsel
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`and without waiving any defenses described or referred to in Rule 12 of the Federal Rules of
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`Civil Procedure, files this Unopposed Motion to Briefly Defer Certain Deadlines.
`
`(1)
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`Response to Micro Motion, Inc.’s Amended Counterclaims. The deadline for
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`Invensys to answer, move, or otherwise respond to Defendant Micro Motion, Inc.’s Amended
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`Answer with Counterclaims is August 1, 2013. Counsel for Micro Motion, Inc. does not oppose
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`Invensys’ request for an 8-day extension of the deadline to answer, move, or otherwise respond
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`to August 9, 2013. The request for extension contained in this motion is the first request by
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`Invensys for an extension of time to answer, move, or otherwise respond. This request for an
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`extension is not sought for purposes of delay and will not affect any other case deadlines.
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`(2)
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`Response to Emerson Electric Co.’s Letter Brief requesting Summary
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`Judgment. The deadline for Invensys to file a Letter Brief with the court opposing Emerson
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`Electric Co.’s request for leave to file a summary judgment motion of non-infringement is
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`August 2, 2013. Counsel for Emerson Electric Co. does not oppose Invensys’ request for a
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`EAST\56948988.1
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`
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`Case 6:12-cv-00799-JRG Document 55 Filed 07/30/13 Page 2 of 3 PageID #: 1651
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`7-day extension of the deadline to file a responsive Letter Brief to August 9, 2013. This request
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`for an extension is not sought for purposes of delay and will not affect any other case deadlines.
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`For these reasons, Invensys respectfully requests that the Court (1) extend the deadline
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`for Invensys to answer, move, or otherwise respond to Micro Motion, Inc.’s Amended Answer
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`with Counterclaims to August 9, 2013, and (2) extend the deadline for Invensys to file a response
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`to Emerson Electric Co.’s Letter Brief requesting Summary Judgment to August 9, 2013.
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`Dated: July 30, 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
`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
`
`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
`
`ATTORNEYS FOR PLAINTIFF
`INVENSYS SYSTEMS, INC.
`
`EAST\56948988.1
`
`
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`Case 6:12-cv-00799-JRG Document 55 Filed 07/30/13 Page 3 of 3 PageID #: 1652
`
`CERTIFICATE OF SERVICE
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`The undersigned certifies that on July 30, 2013, all counsel of record who are deemed to
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`have consented to electronic service are being served with a copy of this document via the
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`Court’s CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served
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`by facsimile transmission and/or first class mail.
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`/s/ Claudia Wilson Frost
`Claudia Wilson Frost
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that he conferred with Defendants’ counsel Kadie M.
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`Jelenchick by email on July 26, 2013, and counsel is not opposed to the relief requested in this
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`motion.
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`/s/ Nicholas G. Papastavros
`Nicholas G. Papastavros
`
`EAST\56948988.1
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