`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Advanced Silicon Technologies LLC,
`
`
`Plaintiff,
`
`v.
`
`NXP Semiconductors N.V.,
`NXP B.V., and
`NXP USA, Inc.,
`
`
`Defendants.
`
`
`
`Case No. 6:22-cv-00466-ADA-DTG
`
`
`
`
`Jury Trial Demanded
`
`Joint Notice of Request to Extend Deadlines to Complete Venue Discovery
`
`Plaintiff Advanced Silicon Technologies LLC and Defendant NXP USA, Inc.1 have
`
`
`
`
`
`conferred and jointly request to extend the deadline for completing venue discovery and, as a
`
`result, the ensuing briefing schedule for Defendant's motion to transfer (ECF No. 46) by 16 days.
`
`The parties seek these extensions to allow for the completion of venue depositions and to account
`
`for the year-end holidays in the ensuing briefing deadlines. The proposed extensions are as follows:
`
`Event
`
`Original Date/Deadline Proposed Date/Deadline
`
`Motion to Transfer Filed
`
`September 12, 2022
`
`(No Change)
`
`Venue Discovery Ends
`
`November 21, 2022
`
`December 7, 2022
`
`Plaintiff's Response Brief
`
`December 5, 2022
`
`December 21, 2022
`
`Defendant's Reply Brief
`
`
`December 19, 2022
`
`January 4, 2023
`
`
`1 The parties filed a joint stipulation of dismissal without prejudice of Defendants NXP
`Semiconductors N.V. and NXP B.V. See ECF No. 34.
`
`—1—
`
`
`
`Case 6:22-cv-00466-ADA-DTG Document 48 Filed 11/16/22 Page 2 of 3
`
`In compliance with the Court's Amended Standing Order Regarding Joint or Unopposed
`
`Request[s] to Change Deadlines, the parties confirm that all parties agree to this request, that this
`
`request does not change the date of any hearing, trial, or other Court date, and that this request
`
`does not extend any deadline of a final submission that affects the Court's ability to hold a
`
`scheduled hearing, trial, or Court event.
`
`For these reasons, the parties jointly request the above modification to the venue discovery
`
`and motion to transfer briefing schedule.
`
`
`
`Dated: November 16, 2022
`
`Respectfully submitted,
`
`
`
`By: /s/ Patrick A. Fitch
`
`
`Brian A. Carpenter (State Bar No. 3840600)
`
`carpenter@caglaw.com
`Carstens, Allen & Gourley, LLP
`1105 Wooded Acres, Suite 415
`Waco, Texas 76701
`(254) 294-1854 (Telephone)
`
`
`Robert R. Brunelli (admitted pro hac vice)
`
`rbrunelli@sheridanross.com
`Patrick A. Fitch (admitted pro hac vice)
`
`pfitch@sheridanross.com
`Alex W. Ruge (admitted pro hac vice)
`
`aruge@sheridanross.com
`Brian Boerman (admitted pro hac vice)
`
`bboerman@sheridanross.com
`Sheridan Ross P.C.
`1560 Broadway, Suite 1200
`Denver, Colorado 80202
`(303) 863-9700 (Telephone)
`(303) 863-0223 (Facsimile)
`litigation@sheridanross.com
`
`Attorneys for Plaintiff
`Advanced Silicon Technologies LLC
`
`
`
`
`
`By: /s/ Eric C. Green
`
`
`Richard S. Zembek (SBN 00797726)
`richard.zembek@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`Fulbright Tower
`1301 McKinney, Suite 5100
`Houston, Texas 77010-3095
`Tel: (713) 651-5151
`Fax: (713) 651-5246
`
`Eric C. Green (SBN 24069824)
`eric.green@nortonrosefulbright.com
`Catherine Garza (SBN 24073318)
`Cat.garza@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`98 San Jacinto Boulevard, Suite 1100
`Austin, Texas 78701
`Tel: (512) 474-5201
`Fax: (512) 536-4598
`
`
`
`
`Counsel for Defendant
`NXP USA, Inc.
`
`—2—
`
`
`
`Case 6:22-cv-00466-ADA-DTG Document 48 Filed 11/16/22 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that, on November 16, 2022, I electronically filed the foregoing with the
`
`Clerk of Court using the CM/ECF system, which will send notification of such filing to all counsel
`
`of record in the above-referenced matter.
`
`
`
`
`
`
`
`
`
`/s/ Thomas J. Armento
`Thomas J. Armento
`Paralegal
`Sheridan Ross P.C.
`1560 Broadway, Suite 1200
`Denver, CO 80202
`(303) 863-9700 (Telephone)
`(303) 863-0223 (Facsimile)
`litigation@sheridanross.com
`
`
`
`—3—
`
`
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