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`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CASE NO. 2:20-cv-00337-JRG
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`Plaintiff,
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`SEAGEN INC.,
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`v.
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`DAIICHI SANKYO CO., LTD.,
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`Defendant.
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`SECOND UNOPPOSED MOTION FOR LEAVE TO CONDUCT DEPOSITION OF
`DR. TRAIL AFTER CLOSE OF CLAIM-CONSTRUCTION DISCOVERY
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`Defendant Daiichi Sankyo Company, Limited respectfully moves for leave to conduct a
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`deposition after close of claim-construction discovery of Plaintiff’s expert regarding claim
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`construction, Dr. Pamela Trail. The Court recently granted an unopposed motion extending the
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`close of claim-construction discovery from July 2, 2021, to July 12, 2021. Defendant is now
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`requesting, and Plaintiff has now agreed to, an extension to Tuesday, July 27, 2021, to take the
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`deposition of Dr. Pamela Trail. Good cause exists here, as the parties and witness were unable to
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`complete this deposition earlier due to scheduling issues and require additional time for Plaintiff
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`to plan for travel to the deposition, which Defendant intends to conduct in person. The requested
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`extension will not affect any other deadlines in this matter.
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`Case 2:20-cv-00337-JRG Document 117 Filed 07/12/21 Page 2 of 3 PageID #: 4489
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`Dated: July 12, 2021
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`Respectfully submitted,
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`/s/ G. Blake Thompson______________
`G. Blake Thompson
`State Bar No. 24042033
`blake@themannfirm.com
`J. Mark Mann
`State Bar No. 12926150
`mark@themannfirm.com
`MANN | TINDEL | THOMPSON
`201 E. Howard St.
`Henderson, Texas 75654
`(903) 657-8540
`(903) 657-6003 (fax)
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`Deron R. Dacus
`State Bar No. 00790553
`The Dacus Firm, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, Texas, 75701
`+1 (903) 705-1117
`+1 (903) 581-2543 facsimile
`ddacus@dacusfirm.com
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`Attorneys for Defendant Daiichi
`Sankyo Company, Limited
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`OF COUNSEL:
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`Preston K. Ratliff II
`Joseph M. O’Malley, Jr.
`Ashley N. Mays-Williams
`Paul Hastings LLP
`200 Park Avenue
`New York, NY 10166
`(212) 318-6000
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`Attorneys for Defendant Daiichi
`Sankyo Company, Limited
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`Case 2:20-cv-00337-JRG Document 117 Filed 07/12/21 Page 3 of 3 PageID #: 4490
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`CERTIFICATE OF SERVICE
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`I hereby certify that counsel of record who are deemed to have consented to electronic
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`service are being served this 12th day of July, 2021, with a copy of this document via the Court’s
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`CM/ECF system per Local Rule CV-5(a)(3).
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`/s/ G. Blake Thompson______________
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`CERTIFICATE OF CONFERENCE
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`The undersigned certifies that Defendant’s counsel has conferred with Plaintiff’s counsel
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`pursuant to Local Rule CV-7(h) and that the foregoing motion is unopposed.
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`/s/ Deron R. Dacus______________
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