Google Inc. v. Rockstar Consortium US LP et al

Filing 96

STIPULATION WITH PROPOSED ORDER Extending Time for Proposed E-Discovery Order filed by Google Inc., Rockstar Consortium U.S. LP, MobileStar Technologies LLC. (Warren, Matthew) (Filed on 7/28/2014) Modified on 7/29/2014 (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)
Kristin J. Madigan
 quinn-google-n.d.cal.-13-05933
@quinnemanuel.com
50 California Street, 22nd Floor

San Francisco, California 94111
 [phone]
[phone] facsimile

Attorneys for Plaintiff Google Inc.


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


UNITED STATES DISTRICT COURT



NORTHERN DISTRICT OF CALIFORNIA



OAKLAND DIVISION


 GOOGLE INC.,

CASE NO. 13-cv-05933-CW



JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
PROPOSED E-DISCOVERY ORDER



Plaintiff,
v.

 ROCKSTAR CONSORTIUM US LP, and
MOBILESTAR TECHNOLOGIES LLC,

Defendants.













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

1

WHEREAS, on Friday, July 18, 2014 (Docket No. 94), the parties stipulated and sought

2 permission of the Court to extend the deadline for submission of a proposed e-discovery order by
3 one week;
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WHEREAS, in its order of Monday, July 21, 2014 (Docket No. 95), the Court granted the

5 parties’ stipulation;
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WHEREAS, under the stipulation and order, the parties have until Monday, July 28, 2014,

7 to file a proposed e-discovery order;
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WHEREAS, since the Court granted the prior stipulation, the parties have conferred and

9 exchanged revised draft proposals of a joint proposed stipulated e-discovery order, but have not
10 yet reached agreement on all issues;
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WHEREAS, the parties wish to present the smallest number of disputed issues, if any, to

12 the Court, and believe a brief extension of one week, until Monday, August 4, 2014, would allow
13 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

16 extension of Defendants’ time to respond to Plaintiff’s complaint (Docket No. 17), a four-week
17 continuance of the Case Management Conference (Docket No. 53), and a further four-day
18 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

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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, August 4, 2014.
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IT IS SO STIPULATED.

5 DATED:

July 28, 2014

Respectfully submitted,

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QUINN EMANUEL URQUHART & SULLIVAN, LLP
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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
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I, Matthew S. Warren, am the ECF User whose userid and password authorized the filing
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of this document.

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

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concurred in this filing.
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DATED: July 28, 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

23 a joint proposed e-discovery order on or before Monday, August 4, 2014.
24 PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
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27 Dated:
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, 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