1

UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

APPLIANCE COMPUTING III, INC.

d/b/a SUREFIELD,

Plaintiff,

v.

REDFIN CORPORATION,

Defendant.

§

§

§

§

§

§

§

§

§

§

Case No. 6:20-cv-00376-ADA

JOINT MOTION FOR ONE-WEEK EXTENSION OF RULE CV-54 DEADLINES

RELATED TO BILL OF COSTS

Plaintiff Appliance Computing III, Inc. d/b/a Surefield (“Plaintiff”) and Defendant Redfin 

Corporation (“Defendant”) (collectively, “the Parties”) hereby stipulate and jointly request1 the 

Court allow one additional week for the Parties to complete their meet and confer efforts on 

Redfin’s proposed Bill of Costs which was filed and served on August 29, 2022. See ECF 247.

On September 6, 2022, Plaintiff notified Redfin of its objections to Redfin’s proposed 

Bill of Costs. Since then, the Parties have met and conferred in an attempt to reach agreement on 

areas of dispute. Under the schedule set by Rule CV-54, the deadline by which a motion may be 

filed indicating the areas of agreement and disagreement on Redfin’s proposed Bill of Cost is 

currently September 19, 2022. See Rule CV-54.a.3 (setting deadline 21 days after the filing of 

the proposed Bill of Costs). However, the Parties anticipate they will need an additional week to 

1 The Parties have submitted this extension request as a joint motion as it affects certain Rule 

CV-54 deadlines concerning the Court clerk, thereby changing “other Court date[s].” See March 

7, 2022 Amended Standing Order Regarding Joint or Unopposed Request to Change Deadlines.

Case 6:20-cv-00376-ADA Document 250 Filed 09/14/22 Page 1 of 4
2

complete their meet and confer efforts. Therefore the Parties request the Court allow a one-week 

extension on this deadline and related Rule CV-54.a.4 deadlines. The Parties’ request for a oneweek extension is not sought for purpose of delay, but to promote efficiency and resolution of 

their disputes, thereby obviating the need to raise such disagreements by motion with the Court.

Accordingly, the Parties respectfully request that the Court extend the following Rule 

CV-54 deadlines by one week as set forth below. A proposed order is submitted herewith.

Current Deadline Amended Deadline Event

September 19, 2022 September 26, 2022 Deadline by which to file Rule CV-54.a.3 

motion.

September 19, 2022 September 26, 2022 Earliest date by which the clerk may tax 

costs if no motion is filed by this date. See 

Rule CV-54.a.4. (“The clerk shall not tax 

costs until the expiration of 21 days after 

the filing of the proposed bill of costs. If 

no motion is filed in that time period, the 

clerk shall proceed to tax costs.”) 

September 26, 2022 October 3, 2022 Date by which costs will be deemed taxed 

as proposed if bill of cost is uncontested 

and if clerk fails to tax costs by this date. 

See Rule CV-54.a.4 (“In a case involving 

an uncontested bill of costs, if the clerk 

fails to tax costs within 28 days after the 

proposed bill of costs is filed, costs will be 

deemed taxed as proposed.”)

Case 6:20-cv-00376-ADA Document 250 Filed 09/14/22 Page 2 of 4
3

Dated: September 14, 2022 Respectfully submitted,

/s/ Nicole E. Glauser

Nicole E. Glauser

Andrew G. DiNovo

Texas State Bar No. 00790594

adinovo@dinovoprice.com

Nicole E. Glauser

Texas State Bar No. 24050694 

nglauser@dinovoprice.com

Christopher V. Goodpastor

Texas State Bar No. 00791991

cgoodpastor@dinovoprice.com

Daniel L. Schmid

Texas State Bar No. 24093118

dschmid@dinovoprice.com

DINOVO PRICE LLP

7000 N. MoPac Expressway, Suite 350 

Austin, Texas 78731

Telephone: (512) 539-2626

Facsimile: (512) 539-2627

Steven W. Fogg (admitted Pro Hac Vice)

sfogg@corrcronin.com

Eric A. Lindberg (admitted Pro Hac Vice)

elindberg@corrcronin.com

CORR CRONIN, LLP

1001 Fourth Avenue, Suite 3900

Seattle, Washington 98154

Telephone: (206) 625-8600

Mark P. Walters (admitted Pro Hac Vice)

walters@lowegrahamjones.com

LOWE GRAHAM JONES, PLLC

701 Fifth Avenue, Suite 4800

Seattle, Washington 98104

Telephone: (206) 381-3300

COUNSEL FOR PLAINTIFF

APPLIANCE COMPUTING III, INC.

d/b/a SUREFIELD

/s/ Ryan Marton

Ryan Marton

Darryl J. Adams

Texas State Bar No. 00796101

dadams@sgbfirm.com

SLAYDEN GRUBERT BEARD PLLC

401 Congress Ave., Suite 1650

Austin, Texas 78701

Telephone: (512) 402-3562

Facsimile: (512) 402-6865

Ryan Marton (admitted Pro Hac Vice)

ryan@martonribera.com

Hector Ribera (admitted Pro Hac Vice)

hector@martonribera.com

Carolyn Chang (admitted Pro Hac Vice)

carolyn@martonribera.com

Phillip Haack (admitted Pro Hac Vice)

phaack@martonribera.com

Marton Ribera Schumann & Chang LLP

548 Market St Suite 36117

San Francisco, CA 94104

Telephone: (415) 360-2515

Benjamin J. Byer (admitted Pro Hac Vice)

benbyer@dwt.com

DAVIS WRIGHT TREMAINE LLP

920 Fifth Avenue, Suite 3300

Seattle, Washington 98104

Telephone: (206) 757-8105

Facsimile: (206) 757-7105 

COUNSEL FOR DEFENDANT

REDFIN CORPORATION

Case 6:20-cv-00376-ADA Document 250 Filed 09/14/22 Page 3 of 4
CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing is being served on the 

counsel of record via the CM/ECF system on September 14, 2022.

By: /s/ Ryan J. Marton

Ryan J. Marton

Case 6:20-cv-00376-ADA Document 250 Filed 09/14/22 Page 4 of 4