Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 292

Consent MOTION for Extension of Time to File Response/Reply as to 263 SEALED PATENT MOTION to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of Non-Privileged Documents on Bedrock's Privilege Log by AOL Inc, Google Inc., Match.Com LLC, MySpace Inc., Yahoo! Inc.. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al Doc. 292 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. 6:09­CV­00269 Hon. Leonard E. Davis JURY TRIAL DEMANDED UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANTS TO FILE THEIR REPLY IN SUPPORT OF THEIR MOTION TO COMPEL NON-PRIVILEGED TESTIMONY AND DOCUMENTS FROM MIKHAIL LOTVIN AND BEDROCK AND REQUEST FOR IN CAMERA REVIEW OF NON-PRIVILEGED DOCUMENTS ON BEDROCK'S PRIVILEGE LOG COME NOW, Defendants Google Inc., Match.com, LLC, MySpace, Inc., AOL Inc., and Yahoo! Inc. ("Defendants") and file this Unopposed Motion for Extension of Time for Defendants to File their Reply in Support of their Motion to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of NonPrivileged Documents on Bedrock's Privilege Log, and would respectfully show the Court as follows: 1. 2. On August 9, 2010, Defendants filed their Motion to Compel [Dkt. #263]. On September 3, 2010, Plaintiff filed its Response in Opposition to Defendants' Motion to Compel, [Dkt. #277]. {A07\7713\0011\W0442401.2 } Dockets.Justia.com 3. On September 9, 2010, Plaintiff filed an Unopposed Motion for Extension of Time for a one week extension to submit proof supporting Bedrock's claim of privilege and work product through September 16, 2010. 4. Defendants' Reply is currently due on September 20, 2010 pursuant to the Court's September 15, 2010 Order. By this Motion, Defendants seek an additional extension to and including September 22, 2010, in which to file their Reply to Plaintiff's Response to Defendants' Motion to Compel. Defendants seek this extension to allow them to address in their reply any proof submitted by Bedrock on September 16, 2010 to support its claim of privilege and work product. 5. Plaintiff does not oppose this extension. WHEREFORE, PREMISES CONSIDERED, Defendants pray that the Court grant this Unopposed Motion for Extension of Time by extending the time period for Defendants to file their Reply in support of their Motion to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of Non-Privileged Documents on Bedrock's Privilege Log up to and including September 22, 2010. Dated: September 20, 2010 Respectfully submitted, By: /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 POTTER MINTON A PROFESSIONAL CORPORATION 110 N. College Ave., Ste. 500 Tyler, Texas 75702 Telephone: (903) 597­8311 Facsimile: (903) 593­0846 Email: mikejones@potterminton.com {A07\7713\0011\W0442401.2 } Claude M. Stern Todd M. Briggs Evette D. Pennypacker QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Telephone: 650­801­5000 Facsimile: 650­801­5100 Email: claudestern@quinnemanuel.com Email: toddbriggs@quinnemanuel.com Email: evettepennypacker@quinnemanuel.com Attorneys for Defendant Match.com LLC and Google, Inc. /s/ Yar Chaikovsky (with permission by Michael E. Jones) Yar R. Chaikovsky ychaikovsky@mwe.com McDERMOTT WILL & EMERY 275 Middlefield Road, Suite 100 Menlo Park, CA 94025 Telephone: (650) 815-7400 Facsimile: (650) 815-7401 Attorneys for Defendant Yahoo! Inc. /s/ Alan Whitehurst (with permission by Michael E. Jones) Alan L. Whitehurst alan.whitehurst@alston.com ALSTON & BIRD LLP The Atlantic Building 950 F Street, N.W. Washington, DC 20004 Telephone: (202) 756-3300 Facsimile: (202) 756-3333 Attorneys for Defendants MySpace, Inc. and AOL LLC. {A07\7713\0011\W0442401.2 } 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) on September 20, 2010. Any other counsel of record will be served by First Class U.S. mail on this same date. /s/ Michael E. Jones {A07\7713\0011\W0442401.2 }