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

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

Unopposed 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. UNOPPOSED MOTION FOR EXTENSION OF TIME TO MOVE, ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendant Samsung Electronics America, Inc. ("Samsung") respectfully moves the Court to extend the time for Samsung to move, answer or otherwise respond to Plaintiff's Complaint for an additional fifteen (15) days up to and including June 28, 2019, and shows the Court as follows: Samsung has obtained extensions of 45 days through the Court's April 24, 2019 Text order, making Samsung's response to Plaintiff's Complaint June 13, 2019. Samsung has just recently retained counsel in this matter and requests the additional time to completely and accurately respond to Plaintiff's Complaint. Counsel for Defendant has conferred with counsel for Plaintiff and Plaintiff is unopposed to the additional 15 days. Samsung files this motion without waiving any potential defenses, including those available under Federal Rule of Civil Procedure 12. WHEREFORE, Samsung respectfully requests that the Court grant this unopposed motion and extend Samsung's deadline for filing a responsive pleading up to and through June 28, 2019. Dated: June 5, 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 CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a) and served via the Court's electronic filing system on all counsel who have consented to electronic service on this 5th day of June, 2019. /s/ Melissa R. Smith Melissa R. Smith 2