Mirror Worlds, LLC v. Apple, Inc.

Filing 50

Unopposed MOTION for Extension of Time to File Apple Inc.'s Unopposed Motion to Amend the Docket Control Order and Discovery Order by Apple, Inc.. (Attachments: # 1 Text of Proposed Order)(Albritton, Eric)

Mirror Worlds, LLC v. Apple, Inc. Doc. 50 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Civil Action No. 6:08-CV-88 LED Plaintiff, v. JURY TRIAL DEMANDED APPLE INC. Defendant. APPLE INC.'S UNOPPOSED MOTION TO AMEND THE DOCKET CONTROL ORDER AND DISCOVERY ORDER Apple Inc. ("Apple"), Defendant in the above-entitled and numbered civil action, moves to amend the Docket Control Order and Discovery Order. In support, Apple will show the following: The Discovery Order (Docket No. 31) entered on September 10, 2008, and the Docket Control Order (Docket No. 32) entered on September 18, 2008 as amended on November 4, 2008 Order (Docket No. 40-2) set the following deadlines: Deadline December 20, 2008 Discovery & Docket Control Orders Items - Comply with P.R. 3-4(a) - Start of Discovery Order 2B document production Accordingly, Apple requests the Court to modify the Discovery & Docket Control Orders as follows: Current Deadline December 20, 2008 New Deadline January 9, 2009 Discovery & Docket Control Orders Items - Comply with P.R. 3-4(a) - Start of Discovery Order 2B document production This extension is not sought for the purpose of delay, but instead so that justice may be served. 1 Dockets.Justia.com WHEREFORE, PREMISES CONSIDERED, the defendant respectfully requests the Court to amend the Docket Control Order as set forth herein above. Respectfully submitted, _______________________________ Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 (903) 757-8449 (phone) (903) 758-7397 (fax) ema@emafirm.com Matthew Powers Lead Attorney Steven Cherensky Sonal N. Mehta (Pro Hac Vice) Stefani C. Smith (Pro Hac Vice) WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (phone) 650-802-3100 (fax) matt.powers@weil.com steven.cherensky@weil.com sonal.mehta@weil.com stefani.smith@weil.com Attorneys for Defendant APPLE INC. 2 CERTIFICATE OF CONFERENCE Counsel for Apple Inc., discussed this motion with Richard An, counsel for the plaintiff, who advised that it is unopposed. _________________________________ Eric M. Albritton CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email, on this the 15th day of December, 2008. _________________________________ Eric M. Albritton 3