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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`Civil Action No. 1:19-cv-11586-FDS
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`PHILIPS NORTH AMERICA LLC,
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`v.
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`FITBIT, INC.,
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`Plaintiff,
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`Defendant.
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`JOINT MOTION TO EXTEND THE TIME TO FILE DISCOVERY
`MOTIONS RELATING TO PLAINTIFF’S MARCH 23, 2021 PRIVILEGE LOG
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` The parties in the above-captioned matter file this joint motion seeking to extend the
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`deadline for Defendant, Fitbit, Inc. (“Fitbit”), to file discovery motions that relate to Plaintiff
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`Philips North America LLC’s (“Philips”) March 23, 2021 privilege log. Fact discovery in this
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`matter closed on March 23, 2021 and the current deadline for filing discovery motions is March
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`31, 2021.
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`This joint motion is supported by good cause. The extension will permit the parties to
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`continue to meet and confer in an effort to resolve pending disputes concerning Philips’s March
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`23, 2021 privilege log without judicial intervention. The extension will not impact any other
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`deadlines in this matter and will not cause prejudice or delay in this action. Further, all parties
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`have agreed to this extension request.
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`WHEREFORE, the Parties respectfully request that the Court grant this Joint Motion to
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`extend the deadline to April 23, 2021 for Defendant to file discovery motions related to
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`Plaintiff’s March 23, 2021 privilege log.
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`Case 1:19-cv-11586-FDS Document 169 Filed 03/31/21 Page 2 of 3
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`Date: March 31, 2021
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`Respectfully Submitted,
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`/s/ Ruben J. Rodrigues
`Lucas I. Silva (BBO 673,935)
`Ruben J. Rodrigues (BBO 676,573)
`John W. Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`lsilva@foley.com
`rrodrigues@foley.com
`jcuster@foley.com
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`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
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`Counsel for Plaintiff
`Philips North America LLC
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`Respectfully Submitted,
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`/s/ Karim Z. Oussayef
`Karim Z. Oussayef (pro hac vice)
`koussayef@desmaraisllp.com
`Leslie M. Spencer (pro hac vice)
`lspencer@desmaraisllp.com
`Brian D. Matty (pro hac vice)
`bmatty@desmaraisllp.com
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`DESMARAIS LLP
`230 Park Avenue
`New York, NY 10169
`Telephone: (212) 351-3400
`Facsimile: (212) 351-3401
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`Ameet A. Modi (pro hac vice)
`amodi@desmaraisllp.com
`Emily H. Chen (pro hac vice)
`echen@desmaraisllp.com
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`DESMARAIS LLP
`101 California Street
`San Francisco, CA 94111
`Telephone: (415) 573-1900
`Facsimile: (415) 573-1901
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`Gregory F. Corbett (BBO # 646394)
`Elizabeth A. DiMarco (BBO#681921)
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02110
`Telephone: (617) 646-8000
`Facsimile: (617) 646-8646
`gcorbett@wolfgreenfield.com
`edimarco@wolfgreenfield.com
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`Attorneys for Fitbit, Inc.
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`SO ORDERED this __ day of ________________ 2020.
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`_________________________________
`UNITED STATES DISTRICT JUDGE
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`Case 1:19-cv-11586-FDS Document 169 Filed 03/31/21 Page 3 of 3
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`LOCAL RULE 7.1(a)(2) CERTIFICATION
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`I, Karim Z. Oussayef, counsel for Defendant, hereby certifies that counsel for Defendant
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`met and conferred with counsel for Plaintiff on March 30, 2021, wherein counsel for Plaintiff
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`stated that they agree to this extension request.
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`/s/ Karim Z. Oussayef
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`CERTIFICATE OF SERVICE
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`I certify that this document is being filed through the Court’s electronic filing system,
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`which serves counsel for other parties who are registered participants as identified on the Notice
`of Electronic Filing (NEF). Any counsel for other parties who are not registered participants are
`being served by first class mail on the date of electronic filing.
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`/s/ Elizabeth A. DiMarco
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