`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`Case No. 6:21-cv-00158-ADA
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`ANSWER OR OTHERWISE RESPOND
`
`Defendant Apple Inc. (“Apple”) hereby moves the Court for an order extending the time
`
`for Apple to answer, move, or otherwise respond to Maxell, Ltd.’s (“Maxell”) Complaint for
`
`Patent Infringement (Dkt. 1). The deadline for Apple to answer, move, or otherwise respond to
`
`Maxell’s Complaint is March 23, 2021. Apple requests a 45-day extension of time to answer,
`
`move, or otherwise respond to Maxell’s Complaint to May 7, 2021. 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 May 7, 2021.
`
`Dated: March 4, 2021
`
`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\293415432.1
`
`
`
`Case 6:21-cv-00158-ADA Document 11 Filed 03/04/21 Page 2 of 2
`
`CERTIFICATE OF CONFERENCE
`
`I hereby certify that 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 4th day of March 2021, 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\293415432.1
`
`- 2 -
`
`
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