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Case 6:20-cv-00896-ADA Document 31 Filed 11/13/20 Page 1 of 3
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`CIVIL ACTION 6:20-CV-00896-ADA
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`PLAINTIFF’S UNOPPOSED MOTION TO ENTER
`[PROPOSED] ORDER REGARDING SERVICE AND ANSWER
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`CAMBRIA COMPANY LLC
`Plaintiff,
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`
`v.
`
`COSENTINO S.A., C & C NORTH
`AMERICA, INC., STONE SYSTEMS OF
`CENTRAL TEXAS, LLC, STONE
`SYSTEMS OF HOUSTON, LLC, STONE
`SYSTEMS OF NEW MEXICO, LLC,
`STONE-MADE PRODUCTS, INC.,
`STONE SUPPLIERS, INC., AND
`QUARTZ SURFACE SUPPLIES, INC.
`Defendants
`
`§
`§
`§
`§
`§
`§
`§
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`§
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`Plaintiff Cambria Company LLC (“Plaintiff”) and Defendants Cosentino S.A., C & C
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`North America, Inc., Stone Systems of Central Texas, LLC, Stone Systems of Houston, LLC,
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`Stone Systems of New Mexico, LLC, Stone-Made Products, Inc., Stone Suppliers, Inc. and Quartz
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`Surface Supplies, Inc. (collectively, “Defendants”) have conferred and reached an agreement
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`regarding service of process and Defendants’ Answer.
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`Plaintiff filed its Complaint in this matter on September 30, 2020 and this Court issued a
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`Summons as to each Defendant on September 30, 2020. Defendants have agreed to waive service
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`of the Summons and Complaint pursuant to Federal Rule of Civil Procedure 4(d) in exchange for
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`an extended timeline—until and including January 8, 2021—to answer or otherwise respond to the
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`Complaint.
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`

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`Case 6:20-cv-00896-ADA Document 31 Filed 11/13/20 Page 2 of 3
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`The Parties have drafted a Proposed Order reflecting this agreement, attached as Exhibit
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`A. Counsel for Defendants has not yet entered an appearance, and as such Plaintiff brings this
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`unopposed motion on behalf of the Parties.
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`WHEREFORE the Parties respectfully move this Court to enter the attached Proposed
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`Order.
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`Date: November 13, 2020
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`2
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`Respectfully Submitted,
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`WINSTON & STRAWN LLP
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`By: /s/ Katherine Vidal
`Katherine Vidal (admitted pro hac vice)
`Eimeric Reig-Plessis (admitted pro hac vice)
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`Telephone: (650) 858-6500
`KVidal@winston.com
`EReigPlessis@winston.com
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`Danielle Williams (admitted pro hac vice)
`300 S. Tryon Street, Suite 1600
`Charlotte, NC 28202
`Telephone: (704) 350-7700
`DWilliams@winston.com
`
`Natalie L. Arbaugh (State Bar No. 24033378)
`M. Brett Johnson (State Bar No. 00790975)
`Alex Wolens (admitted pro hac vice)
`2121 N. Pearl Street, Suite 900
`Dallas, TX 75201
`Telephone: (214) 453-6500
`NArbaugh@winston.com
`MBJohnson@winston.com
`AWolens@winston.com
`
`Jason Z. Pesick (admitted pro hac vice)
`Joseph Becker (admitted pro hac vice)
`35 W. Wacker Drive
`Chicago, IL 60601
`Telephone: (312) 558-5600
`JPesick@winston.com
`JEBecker@winston.com
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`ATTORNEYS FOR PLAINTIFF,
`CAMBRIA COMPANY LLC
`
`
`

`

`Case 6:20-cv-00896-ADA Document 31 Filed 11/13/20 Page 3 of 3
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for both Parties have met and conferred regarding this motion,
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`the Parties are in agreement, and this motion is unopposed.
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`/s/ Katherine Vidal
`Katherine Vidal
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 13, 2020, I caused a true and correct copy of the fore-
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`going to be served on Defendants by delivering a copy to their counsel of record at the email
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`address below:
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`Jennifer H. Roscetti (Jennifer.Roscetti@finnegan.com)
`Jeffrey C. Totten (Jeffrey.Totten@finnegan.com)
`John Palmer (Palmer@namanhowell.com)
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`
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`/s/ Katherine Vidal
`Katherine Vidal
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`3
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`

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`Case 6:20-cv-00896-ADA Document 31-1 Filed 11/13/20 Page 1 of 2
`Case 6:20-cv-00896-ADA Document 31-1 Filed 11/13/20 Page 1 of 2
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`EXHIBIT A
`EXHIBIT A
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`Cosentino Exhibit 1025, Page 4 of 5
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`

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`Case 6:20-cv-00896-ADA Document 31-1 Filed 11/13/20 Page 2 of 2
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`§
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`CIVIL ACTION 6:20-CV-00896-ADA
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`[PROPOSED] ORDER
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`CAMBRIA COMPANY LLC
`Plaintiff,
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`v.
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`COSENTINO S.A., C & C NORTH
`AMERICA, INC., STONE SYSTEMS OF
`CENTRAL TEXAS, LLC, STONE
`SYSTEMS OF HOUSTON, LLC, STONE
`SYSTEMS OF NEW MEXICO, LLC,
`STONE-MADE PRODUCTS, INC.,
`STONE SUPPLIERS, INC., AND
`QUARTZ SURFACE SUPPLIES, INC.
`Defendants
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`
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`
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`Pending before the Court is Plaintiff Cambria Company LLC’s Unopposed Motion to Enter
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`Proposed Order Regarding Service and Answer. Having fully considered the Motion, the Court
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`hereby grants the Motion.
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`IT IS HEREBY ORDERED:
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`1. All Defendants have waived service of the Summons and Complaint pursuant to Federal Rule
`of Civil Procedure 4(d).
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`2. The Summons and Complaint are deemed served upon all Defendants that have not otherwise
`been served previously as of the date of this Order below.
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`3. Defendants shall have until and including January 8, 2021 to answer or otherwise respond to
`the Complaint.
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`
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`SIGNED this ___ day of ___________, 2020.
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`__________________________________
`ALAN D ALBRIGHT
`UNITED STATES DISTRICT JUDGE
`
`

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