Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 260

Agreed MOTION to Stay All Deadlines with Defendants National Instruments Corp., Adobe Systems Inc., Safenet, Inc., Pinnacle Systems, Inc., Onyx Graphics, Inc., Aladdin Knowledge Systems, Inc. and Aladdin Knowledge Systems Ltd. by Uniloc Singapore Private Limited, Uniloc USA, Inc.. (Attachments: # 1 Text of Proposed Order)(Hartsell, Steven)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
UNILOC USA, INC., et al.
Civ. Action No.: 6:10-cv-00472
Plaintiffs,
v.

JURY TRIAL DEMANDED

NATIONAL INSTRUMENTS CORP., et al.
Defendants.

AGREED MOTION FOR STAY OF ALL DEADLINES FOR FISH DEFENDANTS
COMES NOW, Plaintiffs Uniloc USA, Inc. and Uniloc Singapore Limited (“Uniloc”)
and files this Agreed Motion for Stay of All Deadlines in said cause and respectfully requests a
stay of all of deadlines for two weeks as between Uniloc and Defendants National Instruments
Corp., Adobe Systems Inc., Safenet, Inc., Pinnacle Systems, Inc., Onyx Graphics, Inc., Aladdin
Knowledge Systems, Inc. and Aladdin Knowledge Systems Ltd. (together “Fish Defendants”).
The Fish Defendants have assented to the relief sought by this motion.
WHEREFORE, PREMISES CONSIDERED, Uniloc prays that the Court enter the
attached order and stay all pending deadlines up to and including September 30, 2011, and for
such other and further relief as to which it may show itself justly entitled.
Dated: September 15, 2011.

By:
/s/ Steven W. Hartsell
Edward R. Nelson, III
Texas State Bar No. 00797142
Barry J. Bumgardner
Texas State Bar No. 24041918
Steven W. Hartsell
Texas State Bar No. 24040199
S. Brannon Latimer
Texas State Bar No. 24060137
Jaime K. Olin
Texas State Bar No. 24070363
NELSON BUMGARDNER CASTO, P.C.
3131 West 7th Street, Suite 300

Fort Worth, Texas 76107
[phone]
[phone] (fax)
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
T. John Ward, Jr.
Texas State Bar No. 00794818
J. Wesley Hill
Texas State Bar No. 24032294
WARD & SMITH LAW FIRM
111 West Tyler St.
Longview, Texas 75601
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
ATTORNEYS FOR PLAINTIFFS
UNILOC USA, INC. AND
UNILOC SINGAPORE PRIVATE LIMITED

CERTIFICATE OF SERVICE
I hereby certify that on the 15th day of September 2011, I electronically filed the
foregoing document with the clerk of the court for the U.S. District Court, Eastern District of
Texas, Tyler Division, using the electronic case filing system of the court. The electronic case
filing system sent a “Notice of Electronic Filing” to the attorneys of record who have consented
in writing to accept this Notice as service of this document by electronic means.
/s/ Steven W. Hartsell

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