iLOR, LLC v. Google, Inc.

Filing 31

Proposed Agreed Order/Stipulation by iLOR, LLC, Google, Inc.. (Attachments: # 1 Proposed Order Regarding Stipulation)(McGraw, Brian)

iLOR, LLC v. Google, Inc.

Doc. 31

Case 5:07-cv-00109-JMH

Document 31

Filed 09/18/2007

Page 1 of 2

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION at LEXINGTON Electronically Filed iLOR, LLC, Plaintiff, v. GOOGLE INC., Defendant. STIPULATION FOR (1) EXPEDITED DISCOVERY; (2) EXTENSION OF TIME TO OPPOSE PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION; (3) STAY OF PENDING RESPONSE TIME(S); AND (4) TO CONTINUE DATE FOR THE HEARING ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION Pursuant to Local Rule 7.1, IT IS HEREBY STIPULATED, by and between counsel, and subject to the approval of the Court, that: 1) iLOR will respond to Google's first set of requests for production of documents and things (Nos. 1-17) no later than September 24, 2007; 2) Mr. Mansfield will be produced for deposition on a mutually-agreeable date following production of iLOR's documents, and in sufficient time for Google to respond to iLOR's preliminary injunction motion; 3) Google will respond to iLOR's preliminary injunction motion no later than October 3, 2007; 4) The pending deadlines for Google's response to iLOR's preliminary injunction motion will be stayed; 5) The date for the preliminary injunction motion hearing will be continued to November 5, 2007, or as soon thereafter as the Court's calendar permits; and
Dockets.Justia.com

CA No. 5:07-cv-00109-JMH

Case 5:07-cv-00109-JMH

Document 31

Filed 09/18/2007

Page 2 of 2

6)

Google will withdraw its motions filed September 13, 2007 and September 14, 2007. Respectfully submitted,

Dated: September 18, 2007 s/David E. Schmit (with permission, by BPM) __________________________________ David E. Schmit (Ohio Bar #0021147) Frost Brown Todd LLC 2200 PNC Center 201 East Fifth Street Cincinnati, Ohio 45202 [phone] Phone [phone] Fax ATTORNEY FOR PLAINTIFF ILOR, LLC. s/Brian P. McGraw ___________________________________ Frank E. Scherkenbach Peter J. Kirk Matthew J. Leary Fish & Richardson, P.C. 225 Franklin Street Boston, MA 02110-2804 Phone: [phone] Facsimile: [phone] -andJames R. Higgins, Jr. (KBA No. 31790) Brian P. McGraw (KBA No. 90447) Middleton Reutlinger 2500 Brown & Williamson Tower Louisville, KY 40202-3410 Phone: [phone] Facsimile: [phone] ATTORNEYS FOR DEFENDANT GOOGLE INC. CERTIFICATE OF SERVICE It is hereby certified that I electronically filed the foregoing Stipulation with the clerk of the court by using the CM/ECF system, which will send a notice of electronic filing to the following: David E. Schmitt, Frost Brown Todd LLC, 2200 PNC Center, 201 East Fifth Street, Cincinnati, Ohio 45202, counsel for the Plaintiff. s/Brian McGraw ___________________________________ ONE OF COUNSEL FOR DEFENDANT GOOGLE, INC.