STC.UNM v. Intel Corporation

Filing 120

Joint MOTION to Extend (other) Time to Respond to Discovery Objections Under D.N.M. LR-CIV.26.6 by STC. UNM. (Pedersen, Steven) Modified text on 6/30/2011, taking the Motion to Expedite off due to error, per attorneys request (gr).

UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
STC.UNM,
Plaintiff,
v.
INTEL CORPORATION,

No. 10-CV-01077-RB-WDS

Defendant.

UNOPPOSED JOINT MOTION FOR FURTHER EXTENSION OF TIME TO
RESPOND TO DISCOVERY OBJECTIONS UNDER D.N.M. LR-CIV.26.6
The parties hereby respectfully request that the Court enter its Order further extending the
forty-five (45) day time period under D.N.M. LR-Civ.26.6 for an additional sixty (60) days,
during which STC may move to compel regarding its April 15, 2011 request for an inspection of
Intel’s semiconductor fabrication facility D1D, located in Hillsboro, Oregon, under D.N.M. LRCiv.37.1 1
As set forth in its objections, Intel does not believe there are any circumstances under which
STC’s requested inspection is likely to lead to the discovery of admissible evidence. STC
submits that an additional 60 days will permit it to evaluate, in view of other requested
discovery, whether it believes an inspection of Intel’s manufacturing facility is necessary, and
potentially to resolve any disputes before having to proceed under D.N.M. LR-Civ.37.1.
Pursuant to D.N.M. LR-Civ.7.1(a), this Motion is jointly made on behalf of all parties to this
litigation and is unopposed. The parties agree that due to the possibility of avoiding motion
practice on this issue, good cause exists to further extend the current 45 day time period under
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By Order dated March 21, 2011 [Doc. No. 53], the Court extended the period under
D.N.M.LR-Civ.26.6 from twenty-one (21) days to forty-five (45) days for all discovery
objections served in this case.

Local Rule 26.6 for an additional 60 days.
WHEREFORE, for the reasons set forth above, the parties respectfully request that the Court
enter its Order further extending the time period under D.N.M. LR-Civ.26.6 from forty five (45)
days for an additional 60 days for STC to move to compel regarding request for a factory
inspection.

Respectfully submitted,
/s/ Steven R. Pedersen

/s/ Brian L. Ferrall

Deron B. Knoner, Esq.
KELEHER & MCLEOD, P.A.
PO Box AA
Albuquerque, NM 87103
[phone]

Clifford K. Atkinson
Douglas A. Baker
Justin D. Rodriguez
201 Third St. NW, Suite 1850
Albuquerque, New Mexico 87102
[phone]

Rolf O. Stadheim, Esq.
Joseph A. Grear, Esq.
George C. Summerfield, Esq.
Keith A. Vogt, Esq.
Steven R. Pedersen, Esq.
STADHEIM & GREAR, LTD.

Robert A. Van Nest
Brian L. Ferrall
KEKER & VAN NEST LLP
Chad S. Campbell
Jonathan M. James
Timothy J. Franks
Mark E. Strickland
Jonathan L. McFarland
PERKINS COIE LLP

Attorneys for Plaintiff
STC.UNM

Attorneys for Defendant

Intel Corporation

CERTIFICATE OF SERVICE
The undersigned certifies that on the 29th day of June, 2011 the foregoing was filed
electronically through the CM/ECF system, which caused all parties or counsel to be served by
electronic means.
/s/ Steven R. Pedersen

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