`
`IN THE UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`SEAGEN INC.,
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`v.
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`Civil Action No. 2:20-CV-00337-JRG
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`Plaintiff,
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`
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`DAIICHI SANKYO CO., LTD.,
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`Defendant.
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`
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`
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`AGREED MOTION TO EXPEDITE BRIEFING
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`Pursuant to the Court’s Scheduling Order to Govern Discovery and Briefing Pertaining to
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`Jurisdiction and Venue (ECF No. 50), Plaintiff Seagen Inc. (“Plaintiff”) hereby files this Motion
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`to Expedite Briefing on its Motion to Compel Daiichi Sankyo Company, Limited’s (“Defendant”)
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`Discovery Responses and Production (ECF No. 58). The Parties have agreed, and request that
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`Defendant respond to Plaintiff’s Motion to Compel on Friday, February 26, 2021 and that there
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`will be no further briefing. This briefing relates to discovery that Plaintiff purports to seek in
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`connection with Defendant’s pending Motion to Dismiss for Lack of Subject Matter Jurisdiction
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`and Lack of Personal Jurisdiction (Dkt. 22) and Motion to Transfer on the Basis of Inconvenience
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`under 28 U.S.C. § 1404 to the District of Delaware (Dkt. 24). Thus, the Parties are seeking
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`expedited briefing and consideration.
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`
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`1
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`Case 2:20-cv-00337-JRG Document 59 Filed 02/24/21 Page 2 of 3 PageID #: 403
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`Dated: February 24, 2021
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`By: /s/ Michael A. Jacobs w/permission Andrea L.
`Fair
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`Michael A. Jacobs
`MJacobs@mofo.com
`Matthew A. Chivvis
`MChivvis@mofo.com
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, CA 94105
`Telephone: 415.268.7000
`Facsimile: 415.268.7522
`
`Bryan Wilson
`BWilson@mofo.com
`Pieter S. de Ganon
`PdeGanon@mofo.com
`MORRISON & FOERSTER LLP
`755 Page Mill Road
`Palo Alto, California 94304-1018
`Telephone: 650.813.5600
`Facsimile: 650.494.0792
`
`Melissa R. Smith
`Texas State Bar No. 24001351
`melissa@gillamsmithlaw.com
`GILLAM & SMITH, LLP
`303 South Washington Avenue
`Marshall, Texas 75670
`Telephone: 903.934.8450
`Facsimile: 903.934.9257
`Of Counsel:
`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
`Attorneys for Plaintiff Seagen Inc.
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`
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`Case 2:20-cv-00337-JRG Document 59 Filed 02/24/21 Page 3 of 3 PageID #: 404
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that the parties have complied with the meet and confer requirement in
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`Local Rule CV-7(h). On February 19, 22 and 23, 2021, “meet and confer” telephonic conferences
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`of local counsel occurred concerning the relief sought in this motion. The attendees who
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`participated in these telephonic conferences include Andrea Fair (local counsel for Plaintiff Seagen
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`Inc.) and Deron Dacus (local counsel for Defendant Daiichi Sankyo Company Limited). During
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`the conferences, the relief sought in this motion was fully discussed by all parties. Defendant
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`agreed to the relief sought in this motion.
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`/s/ Andrea L. Fair
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`
`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that counsel of record who are deemed to have consented
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`to electronic services are being served with a copy of this document via the Court’s CM/ECF
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`system per Local Rule CV-5(a)(3) on this the 24th day of February, 2021.
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`/s/ Andrea L. Fair
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