John Beck Amazing Profits, LLC v. Google Inc. et al

Filing 22

Submission of Proposed Agreed Docket Control and Discovery Order by John Beck Amazing Profits, LLC, The Rodney A. Hamilton Living Trust. (Attachments: # 1 Text of Proposed Order re Docket Control and Discovery Order)(Fenster, Marc)

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John Beck Amazing Profits, LLC v. Google Inc. et al Doc. 22 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION THE RODNEY A. HAMILTON LIVING TRUST and JOHN BECK AMAZING PROFITS, LLC, Individually and on Behalf of All Others Similarly Situated, Plaintiffs, v. (1) GOOGLE, INC.; AND (2) AOL, LLC Defendants. CLASS ACTION COMPLAINT JURY TRIAL DEMANDED Civil Action No. 2:09-cv-00151-TJW-CE JOINT MOTION FOR ENTRY OF DOCKET CONTROL AND DISCOVERY ORDER Plaintiffs The Rodney A. Hamilton Living Trust and John Beck Amazing Profits, LLC, individually and on behalf of all others similarly situated and Defendants Google Inc. and AOL LLC, respectfully request that, on resolution of the issues of disagreement, as described below, the Court enter the attached proposed Docket Control and Discovery Order. Despite meeting and conferring over several hours, and over several days, the parties were unable to reach agreement on various of the matters discussed pursuant to this Court's October 6, 2009 order and Rule 26(f) of the Federal Rules of Civil Procedure. Accordingly, the attached proposed Docket Control and Discovery Order reflects such areas of disagreement for consideration by the Court. Dated: October 23, 2009 By: /s/ Marc A. Fenster Marc A. Fenster, CA Bar # 181067 Email: mfenster@raklaw.com RUSS, AUGUST & KABAT 12424 Wilshire Boulevard 12th Floor Los Angeles, California 90025 Telephone: 310/826-7474 Facsimile: 310/826-6991 3092-001 091023 JT MT DC-DO Entry.doc 1 Dockets.Justia.com THE RODNEY A. HAMILTON LIVING TRUST and JOHN BECK AMAZING PROFITS, LLC, Individually and on Behalf of All Others Similarly Situated By: /s/ Charles L. Babcock Charles L. "Chip" Babcock TX Bar No. 01479500 Email: cbabcock@jw.com JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 Telephone: 214/953-6030 Facsimile: 214/953-5822 David T. Moran, TX Bar No. 14419400 Email: dmoran@jw.com JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 Telephone: 214/953-6051 Facsimile: 214/661-6677 Carl C. Butzer, TX Bar No. 03545900 Email: cbutzer@jw.com JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 Telephone: 214/953-5902 Facsimile: 214/661-6609 Attorneys for Defendants GOOGLE INC. and AOL LLC 3092-001 091023 JT MT DC-DO Entry.doc 2 CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served on October 23, 2009 with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. Dated: October 23, 2009 /s/ Marc A. Fenster Marc A. Fenster 3092-001 091023 JT MT DC-DO Entry.doc 3