Silvers v. Google, Inc.

Filing 260

Agreed MOTION for Extension of Time to Complete Discovery to Alter Scheduling Order for Non-Expert Discovery Only by Google, Inc., Google, Inc., Stelor Productions,Inc., Stelor Productions, LLC, Stelor Productions, LLC, Steven Esrig. (Attachments: # 1 Proposed Order)(Swing, Morgan)

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Silvers v. Google, Inc. Doc. 260 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 05-80387 CIV RYSKAMP/VITUNAC STEVEN A. SILVERS, an individual, Plaintiff, v. GOOGLE INC., a Delaware corporation, Defendant. _______________________________________/ GOOGLE INC., a Delaware corporation, Counterclaimant, v. STEVEN A. SILVERS, an individual; STELOR PRODUCTIONS, INC., a Delaware Corporation; STELOR PRODUCTIONS, LLC, a Delaware limited liability company, and STEVEN ESRIG, an individual, Counterdefendants. ________________________________________/ AGREED MOTION TO ALTER THE SCHEDULING ORDER RELATING TO NON-EXPERT DISCOVERY ONLY Pursuant to Local Rule 7.1 A.1(j) AND 16.1, the parties, Plaintiffs and Counterdefendants, STELOR PRODUCTIONS, INC. and STELOR PRODUCTIONS, LLC (collectively, "Stelor"), Counterdefendant, STEVEN ESRIG ("Esrig"), and Defendant and Counterclaimant, GOOGLE, INC. ("Google") by and through their respective undersigned counsel, hereby file this Motion to Alter the Scheduling Order Relating to Non-Expert Discovery Only and state as follows: 1. 2. The current non-expert discovery cutoff is July 31, 2008. The parties have endeavored in good faith to complete discovery within the Court's discovery cutoff. During this process they realized the interrelation between the factual and expert discovery. Furthermore, Plaintiff and Counterdefendants have a pending discovery motion. 3. The Parties jointly request an extension of only the non-expert cutoff up to and including September 30, 2008 to coincide with the expert discovery deadline. In this way, all discovery will conclude on September 30, 2008. 4. 5. This request is made for good cause and without the purpose of delay. The parties agree that all other deadlines established by this Court's October 24, 2007 Scheduling Order are to remain the same. WHEREFORE, the parties respectfully request that the Court issue an Order grant their request for additional time within which to complete the non-expert discovery deadline up to and including September 30, 2008, so that all discovery deadline cutoffs are September 30, 2008 and grant such other relief as may be deemed just and proper. Respectfully submitted, s/Kevin C. Kaplan, Florida Bar No. 933848 David J. Zack, Florida Bar No. 641685 Morgan L. Swing, Florida Bar No. 0017092 Email: COFFEY BURLINGTON Office in the Grove, Penthouse 2699 South Bayshore Drive Miami, Florida 33133 Tel: 305-858-2900 Fax: 305-858-5261 Counsel for STELOR PRODUCTIONS, LLC and STEVEN ESRIG Ramsey M. Al-Salam, Esq., Washington Bar. No. 18822 William C. Rava, Esq. Washington Bar No. 29948 PERKINS COIE LLP 1201 Third Avenue Suite 4800 Seattle, WA 98101-3099 Telephone: (206) 359-6338 Facsimile: (206) 359-7338 CERTIFICATE OF SERVICE I hereby certify that on July 3, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the Mailing Information for Case 9:05-cv-80387KLR. I also certify that the foregoing Counsel of record currently identified on the Mailing Information list to receive e-mail notices for this case are served via Notices of Electronic Filing generated by CM/ECF. Counsel of record who are not on the Mailing Information list to receive e-mail notices for this case have been served via U.S. Mail. /s/ Morgan L. Swing

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