`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`Case No. 6:20-cv-00646-ADA
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`APPLE’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`ANSWER OR OTHERWISE RESPOND
`
`Defendant Apple Inc. hereby moves the Court for an order extending the time for Apple
`
`to answer, move, or otherwise respond to Maxell’s Complaint for Patent Infringement (Dkt. 1).
`
`The deadline for Apple to answer, move, or otherwise respond to Maxell’s Complaint is
`
`September 24, 2020. Apple requests a 30-day extension of time to answer, move, or otherwise
`
`respond to Maxell’s Complaint to October 26, 2020. Maxell has agreed to Apple’s request. The
`
`request is not sought for purposes of delay and will not affect any other case deadlines.
`
`Therefore, Apple respectfully requests that the Court extend the deadline for Apple to answer,
`
`move, or otherwise respond to Maxell’s Complaint to October 26, 2020.
`
`Dated: September 24, 2020
`
`Respectfully submitted,
`
`/s/ John M. Guaragna
`John M. Guaragna
`Texas Bar No 24043308
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701-3799
`Tel: 512.457.7125
`Fax: 512.457.7001
`john.guaragna@us.dlapiper.com
`
`ATTORNEY FOR DEFENDANT APPLE INC.
`
`WEST\291856743.1
`
`
`
`Case 6:20-cv-00646-ADA Document 12 Filed 09/24/20 Page 2 of 2
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that the undersigned counsel for Defendant Apple Inc. conferred with
`
`Maxell’s counsel. Maxell has agreed to Apple’s request sought in this motion.
`
`/s/ John M. Guaragna
`John M. Guaragna
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 24th day of September 2020, I electronically filed the
`foregoing with the Clerk of Court using the CM/ECF system, which will send notification of
`such filing via electronic mail to all counsel of record. Any other counsel of record will be
`served by first class U.S. mail.
`
`/s/ John M. Guaragna
`John M. Guaragna
`
`WEST\291856743.1
`
`- 2 -
`
`
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