CNG Financial Corporation v. Google Inc

Filing 46

STIPULATED MOTION for Extension of Summary Judgment Deadline. New date requested 3/30/2007. (Attachments: # 1 Text of Proposed Order)(Hunter, Barry) Modified on 2/22/2007 - To modify docket text (tt1, ).

CNG Financial Corporation v. Google Inc

Doc. 46

Case 1:06-cv-00040-SSB-TSB

Document 46

Filed 02/22/2007

Page 1 of 2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO WESTERN DIVISION
CNG FINANCIAL CORPORATION
Case No. 1 :06-cv-040

Plaintiff/CounterclaimDefendant,
vs.

Chief Judge Sandra S. Beckwith Magistrate Timothy S. Black

GOOGLE INC.
Defendant/Counterclaim- :

STIPULATION, MOTION AND AGREED ORDER TO EXTEND SUMMARY JUDGMENT DEADLINE

Plaintiff.

Plaintiff, CNG Financial Corporation and Defendant Google Inc., through counsel,
hereby stipulate and move the Court for a thirty (30) day extension on the deadline, currently

February 28, 2007, for fiing dispositive motions. In support of this Motion, the parties would
show the Court that the sole reason for this requested extension is that they are currently engaged

in settlement negotiations, and they believe that their time over the next week will be better spent
in attempting to finalize their settlement rather than in finalizing their summary judgment papers.

Indeed, while the complexity of certain issues involved in the settlement talks prevents the
parties from immediately concluding those talks, the parties are optimistic that they will be able
to successfully conclude their settlement talks over the next two to three weeks.

Finally, the Court should note that the parties have not previously asked for any
modification of the Court's schedule for dispositive motions, and the parties respectfully submit

that because the pretrial conference is not scheduled until August 24, 2007, and trial is not
scheduled until September 10, 2007, the brief extension of the dispositive motions deadline

should not require the Court to alter the pretrial or trial settings.

Dockets.Justia.com

Case 1:06-cv-00040-SSB-TSB

Document 46

Filed 02/22/2007

Page 2 of 2

WHREFORE, for the foregoing reasons and to further the parties' settlement efforts, the
parties respectfully move that the Court extend the deadline for fiing dispositive motions

through to and including March 30,2007.
Respectfully submitted,

Isl Barry D. Hunter Ann Gallagher Robinson Frost Brown Todd, LLC 2200 PNC Center 201 East Fifth Street
Cincinnati,OH 45202-4182
Tel. [phone]
Fax: [phone]

Barry D. Hunter Medrith Lee Norman Frost Brown Todd LLC 250 West Main Street, Suite 2700 Lexington, Kentucky 40507 [phone]
(859) 231-001 1-fax

ATTORNYS FOR CNG FINANCIAL CORPORATION
Isl Michael H. Page (with permission) Michael H. Page, Esq. Klaus H. Hamm, Esq. Keker & Van Nest LLP 710 Sansome Street San Francisco, CA 94107
Kenneth F. Seibel, Esq. Jacobs, Kleinman, Seibel & McNally 2300 Kroger Building 1014 Vine Street Cincinnati, OH 45202

ATTORNYS FOR GOOGLE, INC.

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