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).

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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  (415) 875-6600 (415) 875-6700 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) creichman@mckoolsmithhennigan.com McKool Smith Hennigan, P.C. 255 Redwood Shores, CA 94065 (650) 394-1400 (650) 394-1422 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; 4 WHEREAS, in its order of Monday, July 21, 2014 (Docket No. 95), the Court granted the 5 parties’ stipulation; 6 WHEREAS, under the stipulation and order, the parties have until Monday, July 28, 2014, 7 to file a proposed e-discovery order; 8 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; 11 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; 14 WHEREAS, this extension will not otherwise affect the schedule for this case; 15 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); 19 20 21 22 23 24 25 26 27 28 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, August 4, 2014. 4 IT IS SO STIPULATED. 5 DATED: July 28, 2014 Respectfully submitted, 6 QUINN EMANUEL URQUHART & SULLIVAN, LLP 7 By /s Matthew S. Warren Matthew S. Warren Attorneys for Google Inc. 8 9 10 McKOOL SMITH HENNIGAN,P.C. 11 By /s Joshua W. Budwin Joshua W. Budwin Attorneys for Rockstar Consortium US LP and MobileStar Technologies LLC 12 13 14 ATTESTATION 15 I, Matthew S. Warren, am the ECF User whose userid and password authorized the filing 16 of this document. Under Civil Local Rule 5-1(i)(3), I attest that Joshua W. Budwin has 17 concurred in this filing. 18 DATED: July 28, 2014 /s Matthew S. Warren Matthew S. Warren 19 20 21 22 [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. 25 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

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