Mirror Worlds, LLC v. Apple, Inc.

Filing 26

Joint MOTION for Extension of Time to File Agreed Motion for Extension of Time to Submit Agreed Discovery Order and Agreed Docket Control Order by Mirror Worlds, LLC, Apple, Inc.. (Attachments: # 1 Text of Proposed Order)(Stephens, Garland)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 26 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, v. APPLE INC. Defendant. Civil Action No. 6:08-CV-88 JURY TRIAL DEMANDED AGREED MOTION FOR EXTENSION OF TIME TO SUBMIT AGREED DISCOVERY ORDER AND AGREED DOCKET CONTROL ORDER DEFENDANT Apple Inc. ("Apple") and Plaintiff Mirror Worlds LLC ("Mirror Worlds") file this Agreed Motion for Extension of Time to submit their Agreed Discovery Order and Agreed Docket Control Order, and in support thereof would show the Court the following: In its July 29, 2008 Order, the Court set the deadline for submitting the Agreed Discovery Order and Agreed Docket Control Order and the effective Rule 16 Scheduling Conference date at September 2, 2008. Proposed agreed orders have been exchanged by the parties, and arrangements have been made for the parties to meet and confer next week. Accordingly, the parties respectfully jointly request that the time to submit the Agreed Discovery Order and Agreed Docket Control Order be extended one week to Tuesday, September 9. The effective Rule 16 Scheduling Conference shall remain at September 2, 2008. AGREED MOTION FOR EXTENSION OF TIME Dockets.Justia.com Dated: September 2, 2008 Respectfully submitted, _____________/s/________________ Otis Carroll Texas Bar No. 03895700 Lead Attorney Deborah Race Texas Bar No. 16448700 IRELAND, CARROLL & KELLY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 903-561-1600 (Telephone) 903-581-1071 (Facsimile) fedserv@icklaw.com Of counsel: Joseph Diamante Kenneth Stein Richard An JENNER & BLOCK, LLP 919 Third Avenue, 37th Floor New York, NY 10022-3908 212-891-1600 (Telephone) 212-891-1699 (Facsimile) jdiamte@jenner.com ran@jenner.com Attorneys for Plaintiff MIRROR WORLDS, LLC _____________ /s/______________ Garland T. Stephens Texas State Bar No. 24053910 Lead Attorney WEIL, GOTSHAL & MANGES LLP 700 Louisiana St., Suite 1600 Houston, Texas 77002 713-546-5000 (Telephone) 713-224-9511 (Facsimile) garland.stephens@weil.com Sonal N. Mehta (Pro Hace Vice) Stefani C. Smith (Pro Hac Vice) WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (Telephone) 650-802-3100 (Facsimile) sonal.mehta@weil.com stefani.smith@weil.com Attorneys for Defendant APPLE INC. AGREED MOTION FOR EXTENSION OF TIME 2 CERTIFICATE OF SERVICE This is to certify 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) on this the 2nd day of September, 2008. /s/ Kristie Geist Kristie Geist AGREED MOTION FOR EXTENSION OF TIME