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Case 2:23-cv-00059-JRG-RSP Document 325 Filed 02/13/25 Page 1 of 3 PageID #:
`14163
`
`THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
`
`v.
`CHARTER COMMUNICATIONS, INC., et al.,
`Defendants.
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
`
`v.
`COMCAST CABLE COMMUNICATIONS,
`LLC, d/b/a XFINITY, et al.,
`
`Defendants.
`


















`
`
`
`Lead Case No. 2:23-cv-00059-JRG
`Member Case No. 2:23-cv-00062-JRG
`
`COMCAST’S MOTION FOR LEAVE TO FILE ITS OPPOSITION TO
`MOTION TO COMPEL ADDITIONAL DISCOVERY ON COMCAST’S
`SUPPLEMENTAL DISCLOSURES OUT OF TIME
`
`Pursuant to Local Rule 7(k), Defendants Comcast Cable Communications, LLC, Comcast
`
`Corporation, Comcast Cable Communications Management, LLC, and Comcast of Houston,
`
`LLC (together, “Comcast”) move for leave to file its Opposition to Plaintiff’s Motion to Compel
`
`Additional Discovery on Comcast’s Supplemental Disclosures (the “Opposition”) out of time
`
`(Dkt. Nos. 323 and 324). The Court specially set the deadline to file the Opposition to be 12:00
`
`p.m. CST on February 13, 2025 (Dkt. No. 315). Comcast inadvertently filed its Opposition and
`
`attachments after the noon deadline. Comcast apologizes for the error and respectfully requests
`
`the Court grant leave to file its Opposition out of time. Comcast sought confirmation from
`
`counsel for Plaintiff that it does not oppose but did not receive a response before filing the
`
`instant motion for leave. A Proposed Order granting this Motion is attached for the Court’s
`
`convenience.
`
`1
`
`

`

`Case 2:23-cv-00059-JRG-RSP Document 325 Filed 02/13/25 Page 2 of 3 PageID #:
`14164
`
`Dated: February 13, 2025
`
`
`
`
`
`Respectfully submitted,
`
`/s/ David J. Lisson
`Deron Dacus (State Bar No. 00790553)
`THE DACUS FIRM, P.C.
`821 ESE Loop 323, Suite 430
`Tyler, TX 75701
`Tel:
`(903) 705-1117
`ddacus@dacusfirm.com
`
`DAVIS POLK & WARDWELL LLP
`Ashok Ramani (CA Bar No. 200020)
`David J. Lisson (CA Bar No. 250994)
`James Y. Park (CA Bar No. 343659)
`Keon Zemoudeh (CA Bar No. 343023)
`900 Middlefield Road, Suite 200
`Redwood City, CA 94063
`ashok.ramani@davispolk.com
`david.lisson@davispolk.com
`james.park@davispolk.com
`keon.zemoudeh@davispolk.com
`
`Alena Farber (NY Bar No. 5896170)
`450 Lexington Avenue
`New York, NY 10017
`alena.farber@davispolk.com
`
`WILMER CUTLER PICKERING HALE & DORR LLP
`Thomas G. Saunders (DC Bar No. 503012)
`2100 Pennsylvania Avenue, NW
`Washington, DC 20037
`thomas.saunders@wilmerhale.com
`
`Lauren Matlock-Colangelo
`(NY Bar No. 5771340)
`7 World Trade Center
`250 Greenwich Street
`New York, NY 10007
`lauren.matlock-colangelo@wilmerhale.com
`
`Counsel for Defendants Comcast Corporation,
`Comcast Cable Communications, LLC, Comcast
`Cable Communications Management, LLC, and
`Comcast of Houston, LLC
`
`
`
`
`
`2
`
`

`

`Case 2:23-cv-00059-JRG-RSP Document 325 Filed 02/13/25 Page 3 of 3 PageID #:
`14165
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on February 13, 2025 a true and correct copy of the
`
`above and foregoing document has been served on all counsel of record who are deemed to have
`
`consented to electronic service via the Court’s CM/ECF system per Local Rule CV-5(a)(3)(A).
`
`
`
`
`/s/ David J. Lisson
`David J. Lisson
`
`
`
`CERTIFICATE OF CONFERENCE
`
`Comcast sought confirmation from counsel for Plaintiff that it does not oppose but did
`
`not receive a response before filing the instant motion for leave.
`
`
`
`
`
`
`/s/ David J. Lisson
`David J. Lisson
`
`
`
`3
`
`

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