Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 49

MOTION to Shorten Time on Motion to Compel filed by Fusion Garage PTE. LTD. (Attachments: # 1 Proposed Order)(Doolittle, Patrick) (Filed on 4/2/2010)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Claude M. Stern (Bar No. 96737) 2 [e-mail] Patrick Doolittle (Bar No. 203659) 3 [e-mail] 50 California Street, 22nd Floor 4 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] 6 Attorneys for Defendant Fusion Garage PTE Ltd. 7 8 9 10 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CASE NO. C 09-cv-5812 RS (PVT) FUSION GARAGE'S MOTION TO SHORTEN TIME ON ITS MOTION TO COMPEL COMPLIANCE (CIV L.R. 6-3)

11 INTERSERVE, INC. dba TECHCRUNCH, a Delaware corporation, and CRUNCHPAD, 12 INC., a Delaware corporation, 13 14 vs. Plaintiffs,

15 FUSION GARAGE PTE LTD., a Singapore company, 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28
04049.51632/3419433.1

Case No. 09-cv-5812 RS FUSION GARAGE'S MOTION TO SHORTEN TIME

1 2

MOTION TO SHORTEN TIME Pursuant to Civil Local Rule 6-3, Defendant Fusion Garage PTE., Ltd. ("Fusion Garage")

3 respectfully requests that the Court hear Fusion Garage's Motion to Compel Compliance on 4 shortened time. The Motion to Compel requires urgent action because plaintiffs have filed a 5 Motion for a Preliminary Injunction ("PI Motion") yet have produced only a few hundred pages of 6 documents. Fusion Garage served its Requests for Production months ago, and plaintiffs agreed in 7 written discovery responses and written supplemental discovery response that they would be 8 producing documents. To date, with a PI Motion pending, plaintiffs have only produced a small 9 number of documents and are prejudicing Fusion Garage's ability to (i) take a 30(b)(6) deposition 10 related to the opposition to the PI motion; and (ii) prepare their opposition to the PI Motion. 11 As Fusion Garage's opposition to the PI motion is due April 15, 2010, Fusion Garage

12 respectfully requests that the Court hear the Motion to Compel on Wednesday April 7, 2010 with 13 Plaintiffs' opposition due by Monday, April 5, 2010. The Motion to Compel raises a 14 straightforward issue--i.e., should Plaintiffs be required to immediately produce documents they 15 agreed to produce--so Plaintiffs' opposition should require little effort. 16 In accordance with the declaration requirement of Local Rule 6-3, Fusion Garage

17 respectfully refers the Court to the Declaration of Patrick C. Doolittle in support of Fusion 18 Garage's Motion to Compel Compliance. 19 20 21 DATED: April 2, 2010 22 23 24 25 26 27 28
04049.51632/3419433.1

Respectfully submitted, QUINN EMANUEL URQUHART & SULLIVAN, LLP

By

/s/ Patrick Doolittle Patrick C. Doolittle Attorneys for Defendant fusion Garage PTE Ltd.

FUSION GARAGE'S MOTION TO SHORTEN TIME

-1-

Case No. 09-cv-5812 RS