Mirror Worlds, LLC v. Apple, Inc.

Filing 20

Consent MOTION To Extend Deadlines In Compliance With P.R. 3-1 and 3-2 by Mirror Worlds, LLC. (Attachments: # 1 Text of Proposed Order)(Carroll, Otis)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 20 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC VS. APPLE, INC. Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED AGREED MOTION TO EXTEND DEADLINES Plaintiff Mirror Worlds, LLC respectfully submits this Agreed Motion to Extend Deadlines to extend the deadlines set in the Court's June 16, 2008 Order regarding compliance with P.R. 3-1 and 3-2. In accordance with the Court's June 16, 2008 Order and the Court's Patent Rules, Plaintiff is to comply with P.R. 3-1 and 3-2 by July 18, 2008. In order to complete discovery and production relating to those rules, Plaintiff respectfully requests that the deadline for Plaintiff to comply with P.R. 3-1 and 3-2 be extended to and including August 15, 2008. Plaintiff's counsel has conferred with Defendant's counsel, who has agreed to this extension. A draft order granting Plaintiff's motion for extension is attached hereto. Date: July 17, 2008 Respectfully submitted, BY: /s/ Otis Carroll Otis Carroll, Lead Counsel Texas Bar No. 03895700 Deborah Race Texas Bar No. 16448700 IRELAND, CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600 Fax: (903) 581-1071 Email: fedserv@icklaw.com Dockets.Justia.com OF COUNSEL: Joseph Diamante Kenneth Stein Richard An JENNER & BLOCK, LLP 919 Third Avenue, 37th Floor New York, New York 10022-3908 Tel: (212) 891-1600 Fax: (212) 891-1699 Email: jdiamante@jenner.com Email: ran@jenner.com Dr. Gregory J. Gonsalves JENNER & BLOCK, LLP 601 Thirteenth Street, N.W. Suite 1200 South Washington, DC 20005 Tel: (202) 639-6000 Fax: (202) 661-4909 Email: ggonsalves@jenner.com ATTORNEYS FOR PLAINTIFF MIRRORS WORLDS, LLC CERTIFICATE OF CONFERENCE Counsel for Plaintiff has conferred with Garland Stephens, counsel for Defendant, and Defendant does not oppose the relief requested in this motion. /s/ Otis Carroll 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served 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 facsimile transmission and/or first class mail this 17th day of July, 2008. /s/ Otis Carroll 3