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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:21-cv-798
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`GREATGIGZ SOLUTIONS, LLC,
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`WALMART INC.,
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`Plaintiff
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`v.
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`Defendant
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`RESPOND TO COMPLAINT
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`Defendant Walmart Inc. (“Walmart”) hereby moves for an extension of forty-five (45)
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`days to answer or otherwise respond to Plaintiff’s original complaint. The current deadline for
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`Walmart to answer or otherwise respond is September 14, 2021. Walmart seeks an extension to
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`October 29, 2021 as the new deadline for it to answer or otherwise respond to Plaintiff’s
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`complaint. Walmart has conferred with counsel for Plaintiff, which does not oppose this motion.
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`A proposed Order granting this motion has been submitted with this motion.
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`Case 6:21-cv-00798-ADA Document 6 Filed 09/02/21 Page 2 of 2
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`Dated: September 2, 2021
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`Respectfully submitted,
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`/s/ Keith B. Davis
`Hilda C. Galvan
`Lead Attorney
`Texas State Bar No. 00787512
`Email: hcgalvan@jonesday.com
`Keith B. Davis
`State Bar No. 24037895
`kbdavis@jonesday.com
`Christopher A. Buxton
`Texas State Bar No. 24116154
`cbuxton@jonesday.com
`JONES DAY
`2727 North Harwood Street
`Dallas, Texas 75201-1515
`Telephone: (214) 969-4528
`Facsimile: (214) 969-5100
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`Attorneys for Defendant Walmart Inc.
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that all counsel of record who are deemed to have
`consented to electronic service are being served with a copy of this document via the Court’s
`CM/ECF system per Local Rule CV-5(a)(3) on September 2, 2021.
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`/s/ Keith B. Davis
`Keith B. Davis
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for defendant Walmart Inc. conferred with counsel for
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`plaintiff GreatGigz Solutions, LLC on September 2, 2021 and this motion is unopposed.
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`/s/ Keith B. Davis
`Keith B. Davis
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`NAI-1520915460v1
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