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 or Otherwise Respond to Plaintiffs Complaint by Samsung Electronics America, Inc.

Interested in this case?

Current View

Full Text

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-one (31) days up to and including July 29, 2019, and shows the Court as follows: Samsung has obtained an extension of 60 days total through the Court's April 24, 2019 Text Order and June 7, 2019 Text Order, making Samsung's response to Plaintiff's Complaint June 28, 2019. Plaintiff and Defendant have begun initial settlement talks and request the additional time to allow the Parties to explore the possibility of settlement. 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 July 29, 2019. Dated: June 25, 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 25th day of June, 2019. /s/ Melissa R. Smith Melissa R. Smith 2