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)

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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 1 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 (505) 764-8111 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 (505) 842-9150 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 2

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