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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`CIVIL ACTION NO. 6:14-cv-982
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`JURY TRIAL DEMANDED
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`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC,
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`Plaintiff,
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`v.
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`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC.,
`AT&T INC.,
`AT&T MOBILITY LLC,
`VERIZON COMMUNICATIONS, INC.,
`CELLCO PARTNERSHIP D/B/A VERIZON
`WIRELESS,
`SPRINT NEXTEL CORPORATION,
`SPRINT SOLUTIONS, INC.,
`SPRINT SPECTRUM L.P.,
`BOOST MOBILE, LLC,
`T-MOBILE USA, INC., and
`T-MOBILE US, INC.,
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`Defendants.
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`PLAINTIFF’S UNOPPOSED MOTION ON BEHALF OF ALL DEFENDANTS
`TO EXTEND TIME TO RESPOND TO COMPLAINT
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`Plaintiff respectfully moves the Court for an extension of time for all Defendants in this
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`action to respond to Plaintiff’s Complaint. Pursuant to an agreement between Defendant LG
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`Electronics U.S.A., Inc. and Plaintiff concerning service of its foreign parent, LG Electronics,
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`Inc., Plaintiff has agreed to an extension of ninety (90) days.
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`The current deadline for Defendants to move, answer, or otherwise respond to Plaintiff’s
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`Complaint is January 20, 2015. On behalf of Defendants, Plaintiff requests that the Court enter
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`Case 6:14-cv-00982-KNM Document 10 Filed 01/19/15 Page 2 of 3 PageID #: 105
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`an Order extending their deadline to move, answer, or otherwise respond to Plaintiff’s Complaint
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`until and including April 20, 2015. This extension is not meant for improper delay of this
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`proceeding. Defendants will use the additional time to retain outside counsel, review the
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`allegations in the Complaint, and draft the appropriate response. Further, the parties will explore
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`whether early resolution is possible.
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`Dated: January 19, 2015
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`Respectfully submitted,
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`/s/ Edward R. Nelson, III
`Edward R. Nelson, III
`ed@nelbum.com
`Texas State Bar No. 00797142
`Brent N. Bumgardner
`brent@nelbum.com
`Texas State Bar No. 00795272
`Barry J. Bumgardner
`barry@nelbum.com
`Texas State Bar No. 00793424
`S. Brannon Latimer
`brannon@nelbum.com
`Texas State Bar No. 24060137
`Thomas C. Cecil
`tom@nelbum.com
`Texas State Bar No. 24069489
`NELSON BUMGARDNER, P.C.
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`Phone: (817) 377-9111
`Fax: (817) 377-3485
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`T. John Ward, Jr.
`Texas State Bar No. 00794818
`J. Wesley Hill
`Texas State Bar No. 24032294
`Claire Abernathy Henry
`Texas State Bar No. 24053063
`WARD & SMITH LAW FIRM
`P.O. Box 1231
`1127 Judson Rd. Ste. 220
`Longview, Texas 75606-1231
`(903) 757-6400
`(903) 757-2323 (fax)
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`Case 6:14-cv-00982-KNM Document 10 Filed 01/19/15 Page 3 of 3 PageID #: 106
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`jw@jwfirm.com
`wh@wsfirm.com
`claire@wsfirm.com
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`ATTORNEYS FOR PLAINTIFF
`CELLULAR COMMUNICATIONS
`EQUIPMENT LLC
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`CERTIFICATE OF CONFERENCE
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`Pursuant to Local Rule CV-7(h), I certify that the parties have met and conferred and that
`this motion is unopposed.
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`/s/ Edward R. Nelson, III
`Edward R. Nelson, III
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 19th day of January, 2015, I electronically filed the foregoing
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`document with the clerk of the Court for the U.S. District Court, Eastern District of Texas, Tyler
`Division, using the Court’s electronic case filing system. The electronic case filing system sent a
`“Notice of Electronic Filing” to the attorneys of record who have consented in writing to accept
`this Notice as service of this document by electronic means.
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`/s/ Edward R. Nelson, III
`Edward R. Nelson, III
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