F & G Research, Inc. v. Google, Inc.

Filing 64

F & G Research, Inc. v. Google, Inc.

Doc. 64 Att. 1

Case 0:06-cv-60905-CMA

Document 64-2

Entered on FLSD Docket 03/07/2007

Page 1 of 2

EXHIBIT "A"
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 06-60905-CIV-ALTONAGA/Turnoff F&G RESEARCH, INC., Plaintiff, v. GOOGLE INC., Defendant. JOINT MOTION FOR CONTINUANCE OF CLAIM CONSTRUCTION DEADLINES F&G Research, Inc. and Google Inc. (collectively, "the Parties"), by and through their respective counsel, hereby file this Joint Motion for Continuance of the Claim Construction Deadlines ("Joint Motion") and respectfully state as follows. On February 22, 2007, the Court conducted a hearing on Google's Motion for Summary Judgment and Attorneys' Fees ("Summary Judgment Motion") (D.E. #43). At the close of the hearing, the Court directed the Parties to file a report informing the Court of the status of the Summary Judgment Motion on or before March 2, 2007. This directive was memorialized in an Order issued later that day (D.E. #60). On March 2, 2007, the Parties filed a Joint Status Report advising the Court that the Summary Judgment Motion had not been resolved and requesting that the Court rule on the same (D.E. #61). Given the nature of the Summary Judgment Motion, the Parties believe it will be beneficial to resolve the issues presented therein before engaging in claim construction. Accordingly, the Parties respectfully request a continuance of the deadlines relating to claim construction until the Court rules on the Summary Judgment Motion. Specifically, the parties

Dockets.Justia.com

Case 0:06-cv-60905-CMA

Document 64-2

Entered on FLSD Docket 03/07/2007

Page 2 of 2

request a continuance of the deadlines for opening briefs (March 9, 2007); rebuttal briefs (March 23, 2007); and the Markman Hearing (April 2-3), with these dates to be reset, if necessary, at the Court's discretion. A proposed order is attached hereto for the Court's convenience.

Respectfully submitted this 7th day of March, 2007.

s/ Allen Brufsky Allen Brufsky, Esq. Florida Bar Number 133980 [e-mail] CHRISTOPHER & WEISBERG, P.A. 200 East Las Olas Boulevard, Suite 2040 Fort Lauderdale, Florida 33301 Telephone: [phone] Facsimile: (954) 828-19122 Attorneys for Plaintiff, F&G Research, Inc.

s/ Gregory L. Hillyer Gregory L. Hillyer, Esq. Florida Bar Number 682489 [e-mail] FELDMAN GALE, P.A. Miami Center ­ 19th Floor 201 South Biscayne Boulevard Miami, Florida 33131 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant, Google Inc. .

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