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Case 6:12-cv-00799-JRG Document 74 Filed 09/30/13 Page 1 of 3 PageID #: 1888
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`C.A. No. 6:12-cv-00799-LED
`
`JURY TRIAL DEMANDED
`
`§§
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`§
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`§§
`
`§
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`§§
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`§
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`§§
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`§§
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`INVENSYS SYSTEMS, INC.,
`
`v.
`
`Plaintiff,
`
`EMERSON ELECTRIC CO. and
`MICRO MOTION INC., USA,
`
`and
`
`Defendants.
`
`MICRO MOTION INC., USA,
`
`v.
`
`INVENSYS SYSTEMS, INC.,
`
`Counterclaim-Plaintiff, §
`
`§§
`
`§§
`
`Counterclaim-Defendant.§
`
`INVENSYS SYSTEMS, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME
`TO RESPOND TO MICRO MOTION, INC.’S AMENDED ANSWER,
`AFFIRMATIVE DEFENSES, AND SECOND AMENDED COUNTERCLAIMS
`
`Plaintiff and Counterclaim-Defendant Invensys Systems, Inc. (“Invensys”), by and
`
`through the undersigned counsel and without waiving any defenses described or referred to in
`
`Rule 12 of the Federal Rules of Civil Procedure, files this Unopposed Motion For Extension of
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`Time to Respond to Micro Motion, Inc.’s Amended Answer, Affirmative Defenses, and Second
`
`Amended Counterclaims (ECF No. 71).
`
`The deadline for Invensys to answer, move, or otherwise respond to Defendant Micro
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`Motion, Inc.’s Amended Answer, Affirmative Defenses, and Second Amended Counterclaims
`
`(ECF No. 71) is September 30, 2013. Counsel for Micro Motion, Inc. does not oppose Invensys’
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`request for an 8-day extension of the deadline to answer, move, or otherwise respond to October
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`8, 2013. The request for extension contained in this motion is the first request by Invensys for an
`
`EAST\59910222.1
`
`

`
`Case 6:12-cv-00799-JRG Document 74 Filed 09/30/13 Page 2 of 3 PageID #: 1889
`
`extension of time to answer, move, or otherwise respond to this pleading. 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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`Accordingly, Invensys respectfully requests that
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`the Court extend the deadline for
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`Invensys to answer, move, or otherwise respond to Micro Motion, Inc.’s Amended Answer,
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`Affirmative Defenses, and Second Amended Counterclaims (ECF No. 71) to October 8, 2013.
`
`Dated: September 30, 2013
`
`Respectfully submitted,
`
`/s/ Nicholas G. Papastavros
`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\59910222.1
`
`

`
`Case 6:12-cv-00799-JRG Document 74 Filed 09/30/13 Page 3 of 3 PageID #: 1890
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on September 30, 2013, all counsel of record who are
`
`deemed to have consented to electronic service are being served with a copy of this document via
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`the Court’s CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be
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`served by facsimile transmission and/or first class mail.
`
`/s/ Nicholas G. Papastavros
`Nicholas G. Papastavros
`
`CERTIFICATE OF CONFERENCE
`
`The undersigned hereby certifies that he conferred with Defendants’ counsel Kadie M.
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`Jelenchick by email on September 25, 2013, and counsel is not opposed to the relief requested in
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`this motion.
`
`/s/ Nicholas G. Papastavros
`Nicholas G. Papastavros
`
`EAST\59910222.1

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