Neodron LTD v. Dell Technologies, Inc.

Western District of Texas, txwd-6:2019-cv-00318

Unopposed MOTION for Extension of Time to File Answer re [1] Complaint, by Dell Technologies, Inc.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION NEODRON LTD., Plaintiff, v. Civil Action No. 6:19-cv-00318 DELL TECHNOLOGIES INC., Defendant. DEFENDANT DELL TECHNOLOGIES, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Defendant Dell Technologies, Inc. ("Dell") files this unopposed motion for extension of time to answer or otherwise respond to Plaintiff Neodron Ltd.'s ("Plaintiff") Complaint (ECF No. 1). Plaintiff filed its Complaint on May 21, 2019 (ECF No. 1). Plaintiff filed an executed summons with the Court on June 13, 2019, indicating service occurred on May 30, 2019 (ECF No. 10). Assuming that service was proper, Dell's deadline to respond would be June 20, 2019. Dell has recently retained Alston & Bird LLP as counsel. The undersigned counsel for Dell conferred with Plaintiff's counsel on June 17, 2019 to request a 30 day courtesy extension of Dell's time to answer or otherwise respond to Plaintiff's Complaint, and Plaintiff's counsel confirmed that they do not oppose the requested extension. Dell therefore respectfully requests an extension of time up to and including July 22, 2019, to answer or otherwise respond to the Complaint. No prior extension of time has been requested. Accordingly, Dell respectfully requests that the Court issue the attached proposed order extending Dell's time to answer or otherwise respond to Plaintiff's complaint to July 22, 2019. 1 Dated: June 17, 2019 Respectfully submitted, By: /s/ Brady Cox Brady Cox (TX Bar No. 24074084) ALSTON & BIRD LLP 2200 Ross Avenue, Suite 2300 Dallas, Texas 75201 Phone: (214) 922-3400 Fax: (214) 922-3899 brady.cox@alston.com Attorney for Defendant Dell Technologies, Inc. 2 CERTIFICATE OF SERVICE I hereby certify that 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 on June 17, 2019. /s/ Brady Cox Brady Cox 3