Google Inc. v. Rockstar Consortium US LP et al

Filing 94

STIPULATION WITH PROPOSED ORDER Extending Time for Proposed E-Discovery Order filed by Google Inc., Rockstar Consortium US LP, MobileStar Technologies LLC. (Warren, Matthew) (Filed on 7/18/2014) Modified on 7/21/2014 (cpS, COURT STAFF).

1 QUINN EMANUEL URQUHART
& SULLIVAN, LLP
Charles Verhoeven (Cal. Bar No. 170151)

Sean Pak (Cal. Bar No. 219032)
 Matthew S. Warren (Cal. Bar No. 230565)
quinn-google-n.d.cal.-13-05933
@quinnemanuel.com

50 California Street, 22nd Floor
 San Francisco, California 94111
[phone]
 [phone] facsimile

Courtland L. Reichman (SBN 268873)
Mike McKool (Admitted Pro Hac Vice)
Douglas A. Cawley (Admitted Pro Hac Vice)
Ted Stevenson III (Admitted Pro Hac Vice)
David Sochia (Admitted Pro Hac Vice)
[e-mail]
McKool Smith Hennigan, P.C.
255 Redwood Shores, CA 94065
[phone]
[phone] facsimile
Attorneys for Defendants Rockstar Consortium
U.S. LP and MobileStar Technologies LLC

 Attorneys for Plaintiff Google Inc.



UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA



OAKLAND DIVISION

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

GOOGLE INC.,
Plaintiff,

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

v.

CASE NO. 13-cv-05933-CW
JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
PROPOSED E-DISCOVERY ORDER

ROCKSTAR CONSORTIUM US LP, and
 MOBILESTAR TECHNOLOGIES LLC,


Defendants.









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CASE NO. 13-cv-05933-CW
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PROPOSED E-DISCOVERY ORDER

1

WHEREAS, in the joint Case Management Statement filed on Thursday, June 19, 2014,

2 Docket No. 81, the parties indicated that they would “submit a proposed e-discovery order within
3 30 days of filing this document;”
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WHEREAS, in its order of Thursday, June 26, 2014, Docket No. 88, the Court adopted the

5 parties’ Case Management Statement as the Case Management Order except as the Court
6 otherwise indicated;
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WHEREAS, under the Case Management Statement, the parties have until Monday, July

8 21, 2014, to file a proposed e-discovery order;
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WHEREAS, the parties wish to present the smallest number of disputed issues, if any, to

10 the Court, and believe a brief extension of one week, until Monday, July 28, 2014, would allow
11 further discussions toward that end;
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WHEREAS, this extension will not otherwise affect the schedule for this case;

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WHEREAS, the previous modifications of time in this action include a one-week

14 extension of Defendants’ time to respond to Plaintiff’s complaint (Docket No. 17), a four-week
15 continuance of the Case Management Conference (Docket No. 53), and a further four-day
16 extension of Defendants’ time to respond to Plaintiff’s complaint (Docket No. 60);
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CASE NO. 13-cv-05933-CW
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PROPOSED E-DISCOVERY ORDER

1

NOW, THEREFORE, under Civil Local Rule 6-2, the parties stipulate and seek the

2 permission of the Court that the deadline for submission of the proposed e-discovery order be
3 extended one week, to Monday, July 28, 2014.
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IT IS SO STIPULATED.

5 DATED:

July 18, 2014

Respectfully submitted,

6
QUINN EMANUEL URQUHART & SULLIVAN, LLP
7
By /s Matthew S. Warren
Matthew S. Warren
Attorneys for Google Inc.

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McKOOL SMITH HENNIGAN,P.C.

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By /s Joshua W. Budwin
Joshua W. Budwin
Attorneys for Rockstar Consortium US LP and
MobileStar Technologies LLC

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ATTESTATION
I, Matthew S. Warren, am the ECF User whose userid and password authorized the filing

17 of this document.

Under Civil Local Rule 5-1(i)(3), I attest that Joshua W. Budwin has

18 concurred in this filing.
19 DATED: July 18, 2014

/s Matthew S. Warren
Matthew S. Warren

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[PROPOSED] ORDER
The Court having considered the stipulation of the parties, orders that the parties shall file

24 a joint proposed e-discovery order on or before Monday, July 28, 2014.
25 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
26
27 Dated:
28

, 2014
Honorable Claudia Wilken
United States District Judge
CASE NO. 13-cv-05933-CW
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PROPOSED E-DISCOVERY ORDER