`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`AIRE TECHNOLOGY LTD.,
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`Plaintiff,
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`Case No. 6:21-cv-01101-ADA
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`JURY TRIAL DEMANDED
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`v.
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`APPLE INC.,
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`Defendant.
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`JOINT MOTION FOR ENTRY OF AGREED SCHEDULING ORDER
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`Pursuant to the Court’s Order (Dkt. No. 54), Plaintiff Aire Technology Ltd. And Defendant
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`Apple Inc. respectfully request that the Court enter the Parties’ agreed Scheduling Order, attached
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`hereto as Exhibit A, in the above-captioned case.
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`
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`While Apple believes that the proposed Scheduling Order improperly delays adjudication
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`of Apple’s Motion to Transfer as explained in its pending Petition for Writ of Mandamus, Apple
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`jointly submits this proposed Scheduling Order pursuant to the Court’s Order at ECF No. 54
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`directing the parties to do so.
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`
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`Dated: September 6, 2022
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`
`
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`Respectfully submitted,
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`By: /s/ Brett E. Cooper
`
`
`Brett E. Cooper (NY SBN 4011011)
`bcooper@raklaw.com
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`
`
`
`Case 6:21-cv-01101-ADA Document 56 Filed 09/06/22 Page 2 of 3
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`
`Dated: September 6, 2022
`
`
`
`
`Seth Hasenour (TX SBN 24059910)
`shasenour@raklaw.com
`Drew B. Hollander (NY SBN 5378096)
`dhollander@raklaw.com
`
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff Aire Technology
`Limited
`
`
`Respectfully submitted,
`
`By: /s/ J. Stephen Ravel
`
`J. Stephen Ravel
`Texas State Bar No. 16584975
`KELLY HART & HALLMAN LLP
`303 Colorado, Suite 2000
`Austin, Texas 78701
`Tel: (512) 495-6429
`Email: steve.ravel@kellyhart.com
`
`James R. Batchelder (pro hac vice)
`Andrew N. Thomases (admitted in W.D. Tex.)
`Andrew T. Radsch (pro hac vice)
`Daniel W. Richards (pro hac vice)
`ROPES & GRAY LLP
`1900 University Avenue 6th Floor
`East Palo Alto, CA 94303-2284
`Tel: (650) 617-4000
`Fax: (650) 617-4090
`james.batchelder@ropesgray.com
`andrew.thomases@ropesgray.com
`andrew.radsch@ropesgray.com
`daniel.richards@ropesgray.com
`
`
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`2
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`
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`Case 6:21-cv-01101-ADA Document 56 Filed 09/06/22 Page 3 of 3
`
`Cassandra B. Roth (pro hac vice)
`ROPES & GRAY LLP
`1211 Avenue of the Americas
`New York, NY 10036-8704
`Tel: (212) 596-9000
`Fax: (212) 596-9090
`Email: Cassandra.roth@ropesgray.com
`
`Attorneys for Defendant Apple Inc
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record are being served with a copy of the foregoing
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`document via the Court’s CM/ECF system on September 6, 2022.
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`
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`/s/ J. Stephen Ravel
` J. Stephen Ravel
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