`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF OKLAHOMA
`
`
`
`1) MAPLEBEAR, INC., D/B/A
`INSTACART,
`
`
`Plaintiff,
`
`
`v.
`
`
`1) FALL LINE PATENTS, LLC,
`Defendant.
`
`
`
`
`
`Civil Action No. 25-cv-00137-SEH-MTS
`
`
`
`
`
`DEFENDANT’S UNOPPOSED MOTION FOR ADDITIONAL EXTENSION OF
`TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT [DKT. 2]
`COMES NOW Defendant Fall Line Patents, LLC (“Fall Line”), by and through
`
`its counsel of record, respectfully requests an additional extension to May 30, 2025, of its
`
`time to answer or file other responsive pleading to Plaintiff’s Complaint in this case.
`
`1.
`
`The current deadline for Fall Line to Answer or otherwise respond to
`
`Plaintiff’s Complaint is May 16, 2025.
`
`2.
`
`Fall Line seeks additional time because multiple attorneys working on this
`
`case have recently been sick and others have been engaged with hearings and depositions
`
`in other cases. This has interfered with Fall Line’s ability to answer or otherwise respond
`
`by the existing deadline. This extension is not requested for the purposes of delay.
`
`3.
`
`There is currently no scheduling order in this case, there is no trial setting,
`
`and the requested extension will not have any effect on any other deadlines.
`
`4.
`
`Counsel for Plaintiff has no objection to Fall Line’s requested extension of
`
`time to answer or otherwise respond to the Complaint
`
`1
`
`
`
`Case 4:25-cv-00137-SEH-MTS Document 29 Filed in USDC ND/OK on 05/13/25 Page 2 of 3
`
`WHEREFORE, PREMISES CONSIDERED, Defendant Fall Line respectfully
`
`requests that the Court grant Defendant an additional extension until May 30, 2025, to
`
`file its Answer or other responsive pleading.
`
`Dated: May 13, 2025
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`/s/ Rehan M. Safiullah
`
`Michael S. Linscott, OBA No. 17266
`David W. Wulfers, OBA No. 9926
`DOERNER SAUNDERS DANIEL &
`ANDERSON, L.L.P.
`Two West Second Street, Suite 700
`Tulsa, OK 74103-3522
`Telephone: 918.591.5288
`
`Facsimile: 918.925.5288
`Email: mlinscott@dsda.com
`
`dwulfers@dsda.com
`
`Matthew J. Antonelli (pro hac vice)
`Texas Bar No. 24068432
`
`matt@ahtlawfirm.com
`Zachariah S. Harrington (pro hac vice)
`Texas Bar No. 24057886
`zac@ahtlawfirm.com
`Larry D. Thompson, Jr. (pro hac vice)
`Texas Bar No. 24051428
`larry@ahtlawfirm.com
`Rehan M. Safiullah (pro hac vice)
`Texas Bar No. 24066017
`rehan@ahtlawfirm.com
`
`ANTONELLI, HARRINGTON
`& THOMPSON LLP
`4306 Yoakum Blvd., Ste. 450
`Houston, TX 77006
`(713) 581-3000
`
`Attorneys for Defendant
`Fall Line Patents, LLC
`
`
`2
`
`
`
`Case 4:25-cv-00137-SEH-MTS Document 29 Filed in USDC ND/OK on 05/13/25 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 13, 2025, I electronically transmitted the foregoing
`
`document to the Clerk of Court using the ECF System for filing and transmittal of a
`
`Notice of Electronic Filing to the following ECF registrants:
`
`Robert P. Fitz-Patrick
`
`rfitzpatrick@hallestill.com
`
`John R. Hutchins
`
`C. Andy Mu
`
`
`
`
`
`jhutchins@bannerwitcoff.com
`
`amu@bannerwitcoff.com
`
`
`
`
`
`/s/ Rehan M. Safiullah
`Rehan M. Safiullah
`
`
`
`3
`
`
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