`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Civil Action No. 6:20-cv-00802-ADA
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`EXPRESS MOBILE, INC.,
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`
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`v.
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`EBAY INC.,
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`
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`Plaintiff,
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`Defendant.
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`UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO FILE RESPONSE TO
`EBAY’S MOTION TO STAY PENDING RESOLUTION OF MOTION TO TRANSFER
`VENUE AND TO FILE OPPOSITION TO EBAY’S MOTION TO TRANSFER VENUE
`
`Plaintiff Express Mobile, Inc. (“Express Mobile”) files this Unopposed Motion for an
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`Extension of Time to Respond to Defendant’s Motion to Stay Pending Resolution of Motion to
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`Transfer Venue and to Defendant’s Motion to Transfer Venue. The current deadline for Express
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`Mobile to respond to eBay’s motion to stay pending resolution of motion to transfer venue is February
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`18, 2021 and its deadline to respond to eBay’s motion to transfer is February 25, 2021. Express’
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`national counsel are currently preparing for a trial set the week of March 1, 2021. Express Mobile
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`requests the extension so that its counsel will have adequate time to prepare and respond to eBay’s
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`motions.
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`The parties have met, conferred, and agreed to extend these dates and make the new deadline
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`March 11, 2021.
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`Express Mobile respectfully requests that the Court grant this unopposed motion and extend
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`the deadline to respond to eBay’s motion to stay pending resolution of motion to transfer venue and
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`deadline to respond to eBay’s motion to transfer up to and through March 11, 2021
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`1
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`Case 6:20-cv-00802-ADA Document 29 Filed 02/17/21 Page 2 of 3
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`Dated: February 17, 2021
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`Respectfully submitted,
`
`/s/ Robert Christopher Bunt
`Robert Christopher Bunt (Texas 0078716)
`Charles L. Ainsworth (Texas 0783521)
`PARKER, BUNT & AINSWORTH, P.C.
`100 East Ferguson, Suite 418
`Tyler, TX 75702
`Tel: (903) 531-3535
`rcbunt@pbatyler.com
`charley@pbatyler.com
`
`FEINBERG DAY KRAMER ALBERTI LIM
`TONKOVICH & BELLOLI LLP
`Robert F. Kramer (pro hac vice)
`rkramer@feinday.com
`M. Elizabeth Day (pro hac vice)
`eday@feinday.com
`David Alberti (pro hac vice)
`dalberti@feinday.com
`Sal Lim (pro hac vice)
`slim@feinday.com
`Russell S. Tonkovich (pro hac vice)
`rtonkovich@feinday.com
`Marc Belloli (pro hac vice)
`mbelloli@feinday.com
`577 Airport Blvd., Suite 250
`Burlingame, California 94010
`Tel: 650-825-4300
`Fax: 650-460-8443
`
`Attorneys for Plaintiff
`Express Mobile, Inc.
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`CERTIFICATE OF CONFERENCE
`
`In accordance with Local Rule CV-7(i), counsel for the parties have conferred on February
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`17, 2021, regarding the foregoing Motion for Extension of time re Briefing Schedule and Defendant’s
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`counsel has consented to the requested relief.
`
`/s/ Robert Christopher Bunt
` Robert Christopher Bunt
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`1
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`Case 6:20-cv-00802-ADA Document 29 Filed 02/17/21 Page 3 of 3
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
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`that, on February 18, 2021, all counsel of record who have appeared in this case are being served
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`with a copy of the foregoing.
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`February 18, 2021
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`
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`/s/
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`Robert Christopher Bunt
`Robert Christopher Bunt
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`1
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