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Case 2:20-cv-00337-JRG Document 41 Filed 01/27/21 Page 1 of 3 PageID #: 278
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SEAGEN INC.,
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`CIVIL ACTION NO. 2:20-cv-00337
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`Plaintiff,
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`v.
`DAIICHI SANKYO CO., LTD.,
`Defendant.
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`JURY TRIAL DEMANDED
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO
`DEFENDANT’S MOTION TO TRANSFER VENUE (DKT. 24) AND MOTION TO
`DISMISS (DKT. 22)
`
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`Plaintiff Seagen Inc. (“Seagen”) files this Unopposed Motion for Extension of Time to
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`Respond to Defendant’s Motion to Transfer Venue (DKT. 24) and Motion to Dismiss (DKT. 22),
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`showing the Court as follows:
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`Seagen’s deadline to file a response in opposition to Defendant’s motions is February 3,
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`2021. Seagan is requesting an additional 7-day extension of up to and through February 10, 2021,
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`to continue negotiations with Defendant regarding the scope and timing of venue and jurisdictional
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`discovery. The requested extension will not affect any other deadline in this matter.
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`Accordingly, Seagen moves the court for an extension of up to and through February 10,
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`2021 to respond to Defendant’s Motion to Transfer Venue (DKT. 24) and Motion to Dismiss
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`(DKT. 22).
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`sf-4376012
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`

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`Case 2:20-cv-00337-JRG Document 41 Filed 01/27/21 Page 2 of 3 PageID #: 279
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`Dated: January 27, 2021
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`Respectfully submitted,
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`/s/ Melissa R. Smith
`Melissa Smith
`Texas Bar No. 24001351
`Gillam Smith LLP
`303 South Washington Avenue,
`Marshall, Texas 75670
`Phone: 903.934.8450
`Fax: 903.934.9257
`Email: melissa@gillamsmithlaw.com
`
`Michael A. Jacobs (pro hac vice pending)
`MJacobs@mofo.com
`Matthew A. Chivvis (pro hac vice pending)
`MChivvis@mofo.com
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, CA 94105
`Telephone:
`415.268.7000
`Facsimile:
`415.268.7522
`
`Bryan Wilson (pro hac vice pending)
`BWilson@mofo.com
`Pieter S. de Ganon (pro hac vice pending)
`PdeGanon@mofo.com
`MORRISON & FOERSTER LLP
`755 Page Mill Road
`Palo Alto, California 94304-1018
`Telephone:
`650.813.5600
`Facsimile:
`650.494.0792
`
`2
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`

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`Case 2:20-cv-00337-JRG Document 41 Filed 01/27/21 Page 3 of 3 PageID #: 280
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`Of Counsel:
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`T. John Ward, Jr.
`Texas State Bar No. 00794818
`jw@wsfirm.com
`Charles Everingham IV
`Texas State Bar No. 00787447
`ce@wsfirm.com
`Andrea L. Fair
`Texas State Bar No. 24078488
`andrea@wsfirm.com
`WARD, SMITH & HILL, PLLC
`1507 Bill Owens Parkway
`Longview, Texas 75604
`Telephone: 903.757.6400
`Facsimile: 903.757.2323
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`Attorneys for Plaintiff Seagen Inc.
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`document has been served, via the Court’s CM/ECF system per Local Rule CV-5(a) (3) upon all
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`counsel of record on January 27, 2021.
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`/s/ Melissa R. Smith
`Melissa R. Smith
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that Plaintiff has met and conferred with Defendant regarding this Motion
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`via electronic mail on January 26, 2021. Defendant has indicated that it does not oppose this
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`Motion.
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`/s/ Melissa R. Smith
`Melissa R. Smith
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`3
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`

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