Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware


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Case 1:04-cv-00343-JJF Document 181-2 Filed O3/O4/2005 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LGPHILIPS LCD CO., LTD., 1
I
Plaintiff, I
i Civil Action N0. 04-343-IJF
I
v. Q
I
TATUNG COMPANY; et al., i
I
Defendants. i
RULE 7.1 .1 CERTIFICATION
The undersigned counsel certifies, pursuant to Local Rule 7.1.1, that LPL’s counsel
conferred with Tatung’s counsel in an effort to agree to enlarge the time for LPL to tile its
Answering Brief. While consenting generally to the extension of time, Tatung’s counsel insisted
on extending the deadline to a date certain. Because the process before the Special Discovery
Master is just beginning, because the parties have little control over the Special Discovery
Master’s calendar, and because the history of this case demonstrates that obtaining any ordered
discovery Hom the Tatung Defendants will continue to be problematic, LPL believes that setting
the deadline at a definite point after the completion of discovery makes more sense than an
arbitrary date certain that may need to be extended repeatedly.
March 4, 2005 THE BAYARD FIRM
Richa d D. ·Kirk (#922)
222 Delaware Avenue - 9th Floor
Wilmington, DE 19899-5130
(302) 655-5000
Counsel for Plaintiff
LGPHILIPS LCD CO., LTD.
578374vl
4

Case 1:04-cv-00343-JJF

Document 181-2

Filed 03/04/2005

Page 1 of 1