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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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`JURY TRIAL DEMANDED
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`Defendant.
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`FLYP’S UNOPPOSED NOTICE FOR EXTENSION OF TIME
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`Pursuant to the Court’s August 11, 2021, Standing Order Regarding Joint or Unopposed
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`Request to Change Deadlines, Flypsi, Inc. (“Flyp”) files this Unopposed Notice for Extension of
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`Time regarding (1) the deadline for the close of venue discovery, (2) the deadline for Flyp’s
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`response to Google’s Motion to Transfer (Dkt. No. 42) (the “Motion”), and (3) the deadline for
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`Google’s reply in support of its Motion.
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`Google filed its Motion on July 19, 2021. Thereafter, both parties served venue discovery.
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`The parties are now in the process of responding to those requests and negotiating any disputes
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`they may have regarding the same. To provide the parties with additional time to resolve many of
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`their discovery disputes without Court intervention and to accommodate deponent schedules, the
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`Parties have agreed to extend venue discovery and the Motion response and reply deadlines by ten
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`(10) days.
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`Case 6:22-cv-00031-ADA Document 53 Filed 09/15/22 Page 2 of 4
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`As a result, the parties respectfully request that (1) the close of venue discovery be extended
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`to October 7, 2022, (2) Flyp’s response deadline to the Motion be extended to October 21, 2022,
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`and (3) Google’s reply deadline related to the Motion be extended to November 4, 2022.
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`Case 6:22-cv-00031-ADA Document 53 Filed 09/15/22 Page 3 of 4
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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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`DATED: September 15, 2022
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`Case 6:22-cv-00031-ADA Document 53 Filed 09/15/22 Page 4 of 4
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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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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that counsel has complied with the meet and confer
`requirements of Local Rule CV-7(g). Counsel for both parties discussed the issues presented here
`via telephone and email on September 7, 13 and 14. Google indicated that it was not opposed to
`the relief sought herein.
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`/s/ Michael A. Bittner
`Michael A. Bittner
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