Data Scape Limited v. Dropbox, Inc.

Western District of Texas, txwd-6:2019-cv-00023

Unopposed MOTION for Extension of Time to File Response/Reply as to {{32}} MOTION to Change Venue by Data Scape Limited.

Interested in this case?

Current View

Full Text

UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, C.A. No. 6:19-cv-00023-ADA Plaintiff, v. JURY TRIAL DEMANDED DROPBOX, INC., Defendant. UNOPPOSED MOTION TO EXPAND PAGE LIMITS FOR AND EXTEND TIME TO FILE OPPOSITION BRIEF TO DEFENDANT'S MOTION TO TRANSFER VENUE TO THE HONORABLE ALAN D. ALBRIGHT, UNITED STATES DISTRICT JUDGE: Comes Now, Data Scape, Ltd. ("Data Scape") and files its Unopposed Motion to (1) expand page limits for and (2) extend time to file its Opposition to Defendant Dropbox, Inc.'s ("Dropbox") Motion to Transfer Venue to the United States District Court for the Northern District of California (Dkt. No. 31) and as grounds therefore would respectfully show the Court as follows. Data Scape, by this Motion, requests no more than twenty pages to file its Opposition to Dropbox's Motion to Transfer. Data Scape did not oppose Dropbox's request for the same enlargement of page numbers, which was granted by the Court this morning. Data Scape believes it requires the same number of additional pages allotted to Dropbox to adequately oppose Dropbox's motion. As set forth in the certificate of conference below, Dropbox agreed to this request and that its request for ten additional pages would be mutual. Likewise, because Dropbox received twice the standard number of pages to prepare it Motion, Data Scape requests an extension of time of one week to respond to the motion. This would make Data Scape's Opposition due on May 8, 2019. Dropbox agreed to this request in exchange for Data Scape agreeing not to oppose Dropbox's request for additional pages. Dated: April 25, 2019 Respectfully submitted, /s/ Paul A. Kroeger Marc A. Fenster (CA SBN 181067) Reza Mirzaie (CA SBN 246953) Brian D. Ledahl (CA SBN 186579) Paul A. Kroeger (CA SBN 229074) C. Jay Chung (CA SBN 252794) Philip X. Wang (CA SBN 262239) RUSS AUGUST & KABAT 12424 Wilshire Boulevard, 12th Floor Los Angeles, CA 90025 (310) 826-7474 mfenster@raklaw.com rmirzaie@raklaw.com bledahl@raklaw.com 1 pkroeger@raklaw.com jchung@raklaw.com pwang@raklaw.com Robert M. O'Boyle CLARK HILL LLP 720 Brazos Street, Suite 700 Austin, Texas 78701 Email: bob.oboyle@clarkhillstrasburger.com Telephone: (512) 499-3644 Facsimile: (512) 536-5707 Attorneys for Plaintiff Data Scape Limited 2 CERTICATE OF CONFERENCE Counsel for the parties conferred by telephone on April 22, 2019. Defendant agreed not to oppose Plaintiff's request for ten additional pages and a seven day extension of time to file its opposition brief in exchange for Plaintiff agreeing not to oppose Defendant's request for additional pages for its motion. /s/ Paul A. Kroeger 3 CERTIFICATE OF SERVICE The undersigned certifies that on April 25, 2019, all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system pursuant to Local Rule CV-5(a)(3)(A). /s/ Paul A. Kroeger 4