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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`FLYPSI, INC. (D/B/A FLYP),
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`Plaintiff,
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`Civil Action No. 6:22-cv-31-ADA
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`vs.
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`GOOGLE LLC,
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`Defendant.
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`JURY TRIAL DEMANDED
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`JOINT MOTION FOR ENTRY OF AMENDED SCHEDULING ORDER
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`Plaintiff Flypsi, Inc. (“Flyp”) and Defendant Google LLC (“Google”) file this Joint Motion
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`for Entry of an Amended Scheduling Order.
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`Following resolution of the parties’ discovery dispute (Dkt. No. 96), the parties have been
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`unable to agree on a schedule to govern the case moving forward and jointly request that the Court
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`enter a schedule with either Flyp or Google’s proposed deadlines as set forth in the attached
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`Amended Scheduling Order. Regarding the parties’ disagreement, Flyp submits that the trial date
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`should remain unchanged because Google’s Motion to Stay was denied and has proposed
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`reasonable extensions to certain discovery deadlines to account for a new contention deadline
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`while leaving later case deadlines intact. Google submits that all case deadlines, including trial,
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`should be shifted to account for the new contention deadline, and that Flyp’s proposal is
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`unreasonable both in its (1) discovery period extension (i.e. adding 2 weeks to the current
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`discovery deadlines where final contentions have been pushed by nearly 10 weeks) and (2)
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`Case 6:22-cv-00031-ADA Document 100 Filed 03/03/23 Page 2 of 4
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`compression of post-discovery dates (e.g., making the Dispositive and Daubert motions deadline
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`the same day as Pretrial Disclosures).
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`DATED: March 3, 2023
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`Respectfully submitted,
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`/s/ Michael A. Bittner
`Thomas M. Melsheimer
`Texas Bar No. 13922550
`tmelsheimer@winston.com
`M. Brett Johnson
`Texas Bar No. 00790975
`mbjohnson@winston.com
`Michael A. Bittner
`Texas Bar No. 24064905
`mbittner@winston.com
`WINSTON & STRAWN LLP
`2121 North Pearl Street, Suite 900
`Dallas, TX 75201
`Telephone: (214) 453-6500
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`Matthew R. McCullough
`California Bar No. 301330
`mrmccullough@winston.com
`WINSTON & STRAWN LLP
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`Telephone: (650) 858-6500
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`William M. Logan
`Texas Bar No. 24106214
`wlogan@winston.com
`WINSTON & STRAWN LLP
`800 Capitol Street, Suite 2400
`Houston, TX 77002
`Telephone: (713) 651-2766
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`ATTORNEYS FOR PLAINTIFF
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`Case 6:22-cv-00031-ADA Document 100 Filed 03/03/23 Page 3 of 4
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`
`/s/ Robert W. Unikel (with permission)
`Paige Arnette Amstutz
`State Bar No.: 00796136
`pamstutz@scottdoug.com
`SCOTT, DOUGLASS & MCCONNICO, LLP
`303 Colorado Street, Suite 2400
`Austin, TX 78701
`Telephone: (512) 495-6300
`Facsimile: (512) 495-6399
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`Robert W. Unikel (Pro Hac Vice)
`robertunikel@paulhastings.com
`John A. Cotiguala (Pro Hac Vice)
`johncotiguala@paulhastings.com
`Daniel J. Blake (Pro Hac Vice)
`danielblake@paulhastings.com
`Grayson S. Cornwell (Pro Hac Vice)
`graysoncornwell@paulhastings.com
`PAUL HASTINGS LLP
`71 South Wacker Drive, Suite 4500
`Chicago, IL 60606
`Telephone: (312) 499-6000
`Facsimile: (312) 499-6100
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`Robert R. Laurenzi (Pro Hac Vice)
`robertlaurenzi@paulhastings.com
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 319-4090
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`Elizabeth Brann (Pro Hac Vice)
`elizabethbrann@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
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`Joshua Yin (Pro Hac Vice)
`joshuayin@paulhastings.com
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`DATED: March 3, 2023
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`Case 6:22-cv-00031-ADA Document 100 Filed 03/03/23 Page 4 of 4
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`David M. Fox (Pro Hac Vice)
`davidfox@paulhastings.com
`Alex Rhim (Pro Hac Vice)
`alexrhim@paulhastings.com
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, CA 94304
`Telephone: (650) 320-1800
`Facsimile: (650) 320-1900
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`Attorneys for Defendant Google LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that a copy of the foregoing document was filed electronically in
`compliance with Local Rule CV-5. Therefore, this document was served on all counsel who are
`deemed to have consented to electronic service. Administrative Policies and Procedures for
`Electronic Filing in Civil and Criminal Cases, Western District of Texas, Section 14.
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`/s/ Michael A. Bittner
`Michael A. Bittner
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