STC.UNM v. Intel Corporation

Filing 123

Joint MOTION for Extension of Time to File Response/Reply as to 109 Order to Discovery Objections Under D.N.M. LR-Civ.26.6 by Intel Corporation. (Rodriguez, Justin)

UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
STC.UNM,

Case No. 10-CV-01077-RB-WDS
Plaintiff,

v.
INTEL CORPORATION,
Defendant.

UNOPPOSED JOINT MOTION FOR FURTHER EXTENSION OF TIME TO RESPOND
TO DISCOVERY OBJECTIONS UNDER D.N.M. LR-CIV.26.6
The parties respectfully request that the Court enter an Order further extending the time
period as set by the Court’s June 17, 2011 Order [Doc. No. 109] for an additional twenty-one
(21) days, during which time Intel may move to compel regarding STC’s May 2, 2011 privilege
logs and responses to Intel’s discovery request under D.N.M LR-Civ.37.1. The parties
previously agreed to extend the time period for moving to compel by twenty-one (21) days. The
parties used the prior extension to meet and confer and have successfully resolved most of their
remaining disputes. STC requires additional time to produce certain documents, update its
privilege logs, and consider Intel’s remaining concerns. Consequently, the parties request an
additional 21 days 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 nature and scope of discovery
in this case, good cause exists to further extend the deadline so the parties can resolve their
disputes without having to burden the Court with unnecessary motions practice.
WHEREFORE, for the reasons set forth above, the parties respectfully request that the
Court enter its Order further extending the time period under its June 17, 2011 Order for an
additional twenty-one (21) days for Intel to move to compel documents regarding STC’s May 2,

567991.01

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2011 privilege logs and responses to Intel’s discovery requests.
Dated: July 7, 2011
Respectfully submitted,
ATKINSON, THAL & BAKER, P.C.
/s/ Justin D. Rodriguez________
Clifford K. Atkinson
Douglas A. Baker
Justin D. Rodriguez
201 Third Street NW, Suite 1850
Albuquerque, New Mexico 87102
[phone]
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 Defendant
Intel Corporation
AND
/s/ Keith Vogt (via email)______
Deron B. Knoner, Esq.
KELEHER & MCLEOD, P.A.
PO Box AA
Albuquerque, NM 87103
[phone]
George C. Summerfield, Esq.
Joseph A. Grear, Esq.
Keith A. Vogt, Esq.
Rolf O. Stadheim, Esq.
Steven R. Pedersen, Esq.
STAHEIM & GREAR, LTD.
Attorneys for Plaintiff
STC.UNM

567991.01

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