Filing 34

Joint MOTION for Discovery -- Modification of Scheduling by AGENCE FRANCE PRESSE, GOOGLE INC.. (Attachments: # 1 Text of Proposed Order)(Bain, Scott)

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AGENCE FRANCE PRESSE v. GOOGLE INC. Doc. 34 Case 1:05-cv-00546-GK Document 34 Filed 01/09/2006 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA AGENCE FRANCE PRESSE, Plaintiff and Counter Defendant v. GOOGLE INC., Defendant and Counter Claimant ) ) ) ) ) ) ) Civil Action No. 1:05CV00546 (GK) Next Due Date: March 21, 2006 (Status Conference) JOINT MOTION FOR MODIFICATION OF SCHEDULING ORDER Plaintiff/Counter Defendant Agency France Press ("AFP") and Defendant/Counter Claimant Google Inc. ("Google") hereby jointly move the Court for modification of the Court's Scheduling Order dated June 20, 2005. The parties jointly propose to extend the discovery schedule by 60 days. Thus, Proponent's Rule 26(a)(2) Statements, which are currently due January 16, 2006, would be due March 16, 2006, and Opponent's Rule 26(a)(2) Statements, which are currently due March 16, 2006, would be due May 16, 2006. A Joint Praecipe informing the Court of the status of discovery would be due on March 16, 2006. The deadline for the close of discovery would be extended from April 1, 2006 to June 1, 2006, and the deadline for filing dispositive motions would be extended from May 31, 2006 to July 31, 2006. We leave it up to the Court to determine an appropriate date for the Pretrial Conference, which has not been scheduled. In the Court's Scheduling Order, Your Honor proposed March 21, 2006 for a status conference. We leave it up to Your Honor to decide whether this date should be extended in light of the requested modifications to the scheduling order. There is good cause for the requested extensions. The parties have made limited progress in discovery due to a fundamental disagreement over the scope of the case and the identification of the works in suit. The parties are currently investigating the technical feasibility of an 1 Case 1:05-cv-00546-GK Document 34 Filed 01/09/2006 Page 2 of 2 approach that would narrow the scope of the controversy and streamline discovery. The requested extensions would provide the parties with needed time to complete discovery once the disagreement is resolved. Also, the Court's consideration of several pending motions to be argued January 11, 2006 may provide useful guidance to the parties. A proposed Order is attached. Respectfully submitted, By: /s/ Thomas W. Kirby Andrew G. McBride, Bar No. 426697 Bruce G. Joseph, Bar No. 338236 Thomas W. Kirby, Bar No. 915231 Scott E. Bain, Bar No. 466657 Wiley Rein & Fielding LLP 1776 K Street, N.W. Washington, D.C. 20006 (202) 719-7000 (202) 719-7049 (fax) Counsel for Google Inc. /s/ Joshua Kaufman (w/ permission) Joshua J. Kaufman, Bar No. 945188 Mary Jane Saunders, Bar No. 436608 VENABLE LLP 575 7th Street, NW Washington, D.C. 20004-1601 (202) 344-8538 (phone) (202) 344-8300 (fax) Counsel for Agence France Presse January 9, 2006 2

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