Ceglia v. Zuckerberg et al

Filing 468

MOTION for Extension of Time to Complete Discovery and to Modify Minute and Order (Doc. No. 348) on Consent of All Parties by Facebook, Inc., Mark Elliot Zuckerberg.(Snyder, Orin)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
-----------------------------------PAUL D. CEGLIA,
Plaintiff,
v.
MARK ELLIOT ZUCKERBERG and
FACEBOOK, INC.,

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NOTICE OF MOTION TO
MODIFY MINUTE AND
ORDER ON CONSENT OF ALL
PARTIES
Civil Action No. 1:10-cv-00569RJA

Defendants.
-----------------------------------PLEASE TAKE NOTICE that upon the annexed Declaration of Alexander H.
Southwell, Esq., the undersigned hereby moves this Court, on consent of all parties, for an Order
modifying the currently-scheduled deadline to conclude expert depositions (with the exception of
Plaintiff's expert Mr. Erich Speckin, as described in the annexed Southwell Declaration).
Specifically, the parties jointly request a ten-day extension of the currently-scheduled deadline to
conclude expert depositions from August 4, 2012 to August 14, 2012. The parties' deadlines to
submit opposition and reply filings regarding Defendants' motions to dismiss, set forth in the
Court’s Minute and Order (Doc. No. 348), would continue to be two months after the close of
expert depositions and thirty days after submission of Plaintiff's opposition, respectively.
PLEASE TAKE FURTHER NOTICE that, because all parties seek the proposed
modification, Defendants do not request oral argument on this motion and state their intention to
file and serve reply papers only if necessary.

Dated:

New York, New York
August 3, 2012
Respectfully submitted,
/s/ Orin Snyder
Orin Snyder
Alexander H. Southwell
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue, 47th Floor
New York, NY 10166-0193
[phone]

Thomas H. Dupree, Jr.
GIBSON, DUNN & CRUTCHER LLP
1050 Connecticut Avenue, NW
Washington, DC 20036
[phone]
Terrance P. Flynn
HARRIS BEACH PLLC
726 Exchange Street
Suite 1000
Buffalo, NY 14210
[phone]

Attorneys for Defendants Mark Zuckerberg and Facebook, Inc.

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