BCS Software, LLC v. Samsung Electronics America, Inc.

Western District of Texas, txwd-6:2019-cv-00235

Joint MOTION for Extension of Time to File Answer by Samsung Electronics America, Inc.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION BCS SOFTWARE, LLC, Plaintiff, Case No.: 6:19-cv-00235-ADA v. SAMSUNG ELECTRONICS AMERICA, INC., Defendant. JOINT MOTION FOR EXTENSION OF TIME TO MOVE, ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Plaintiff BCS Software, LLC and Defendant Samsung Electronics America, Inc. ("Parties") respectfully move the Court to extend the time for Samsung to move, answer or otherwise respond to Plaintiff's Complaint for an additional thirty (30) days up to and including August 28, 2019, and shows the Court as follows: Plaintiff and Defendant are actively meeting and conferring to resolve this matter or streamline a planned motion in response to Plaintiff's Complaint. The Parties file this motion without waiving any potential defenses for Samsung, including those available under Federal Rule of Civil Procedure 12. WHEREFORE, the Parties respectfully request that the Court grant this joint motion and extend Samsung's deadline for filing a responsive pleading up to and through August 28, 2019. Dated: July 26, 2019 Respectfully submitted, By: /s/ Melissa R. Smith Melissa Smith State Bar No. 24001351 LOCAL COUNSEL GILLAM & SMITH LLP 303 S. Washington Avenue Marshall, TX 75670 Telephone: (903) 934-8450 Facsimile: (903) 934-9257 Email: melissa@gillamsmithlaw.com Counsel for Defendant By: /s/ Raymond W Mort, III Raymond W Mort, III The Mort Law Firm, PLLC 100 Congress Ave, Suite 2000 Austin, TX 78701 512-865-7950 Fax: 512-865-7950 Email: raymort@austinlaw.com Counsel for Plaintiff CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5 and served via the Court's electronic filing system on all counsel who have consented to electronic service on this 26th day of July, 2019. /s/ Melissa R. Smith Melissa R. Smith 2