Case 6:22-cv-00031-ADA Document 106 Filed 04/03/23 Page 1 of 5
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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 the parties’ dispute regarding certain scheduling issues (see Dkt. No. 100), the
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`Court issued an Amended Scheduling Order (Dkt. No. 102) modifying certain deadlines to govern
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`the remainder of this case. One deadline, however, appeared to have been inadvertently
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`unmodified in the Court’s Amended Scheduling Order—namely, the deadline to “File Joint
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`Pretrial Order and Pretrial Submissions (jury instructions, exhibits lists, witness lists, discovery
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`and deposition designations); file oppositions to motions in limine” remained set for October 4,
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`2023. Because motions in limine are not due to be filed until October 11, 2023, the parties jointly
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`request that the above deadline be modified by the same two-week extension received by the other
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`September to November pretrial deadlines in the Court’s Amended Scheduling Order, as
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`demonstrated below.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`FLYPSI, INC. (D/B/A FLYP),
`
`
`
`
`
`
`
`Plaintiff,
`
`Civil Action No. 6:22-cv-31-ADA
`
`vs.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`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
`
`for Entry of an Amended Scheduling Order.
`
`Following the parties’ dispute regarding certain scheduling issues (see Dkt. No. 100), the
`
`Court issued an Amended Scheduling Order (Dkt. No. 102) modifying certain deadlines to govern
`
`the remainder of this case. One deadline, however, appeared to have been inadvertently
`
`unmodified in the Court’s Amended Scheduling Order—namely, the deadline to “File Joint
`
`Pretrial Order and Pretrial Submissions (jury instructions, exhibits lists, witness lists, discovery
`
`and deposition designations); file oppositions to motions in limine” remained set for October 4,
`
`2023. Because motions in limine are not due to be filed until October 11, 2023, the parties jointly
`
`request that the above deadline be modified by the same two-week extension received by the other
`
`September to November pretrial deadlines in the Court’s Amended Scheduling Order, as
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` 1
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`
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`demonstrated below.
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`Case 6:22-cv-00031-ADA Document 106 Filed 04/03/23 Page 2 of 5
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`October 4, 2023
`October 4, 2023
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`October 11, 2023
`October 18, 2023
`(changed from October
`4, 2023)
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`October 25, 2023
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`November 3, 2023
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`Serve objections to pretrial disclosures/rebuttal disclosures.
`Parties to jointly email the Court’s law clerk (See OGP at 1) to
`confirm their pretrial conference and trial dates.
`Serve objections to rebuttal disclosures; file Motions in limine.
`File Joint Pretrial Order and Pretrial Submissions (jury instructions,
`exhibits lists, witness lists, discovery and deposition designations);
`file oppositions to motions in limine
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`File Notice of Request for Daily Transcript or Real Time Reporting.
`If a daily transcript or real time reporting of court proceedings is
`requested for trial, the party or parties making said request shall file a
`notice with the Court and email the Court Reporter, Kristie Davis at
`kmdaviscsr@yahoo.com
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`Deadline to meet and confer regarding remaining objections and
`disputes on motions in limine.
`File joint notice identifying remaining objections to pretrial
`disclosures and disputes on motions in limine.
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`The parties do not request modification of any other deadlines via this Motion. A Proposed
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`Order is attached for the Court’s convenience.
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`Case 6:22-cv-00031-ADA Document 106 Filed 04/03/23 Page 3 of 5
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`DATED: April 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 106 Filed 04/03/23 Page 4 of 5
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`/s/ Paige Amstutz (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: April 3, 2023
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`Case 6:22-cv-00031-ADA Document 106 Filed 04/03/23 Page 5 of 5
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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, on April 3, 2023, 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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