Datatreasury Corporation v. Wells Fargo & Company et al

Filing 348

Joint MOTION for Extension of Time to File Joint Motion to Extend Deadlines Set Forth In Order From Scheduling Conference and Docket Control Order by Datatreasury Corporation, Datatreasury Corporation, Datatreasury Corporation, Bank of America Corporation, Bank of America, National Association, Datatreasury Corporation. (Attachments: #1 Text of Proposed Order)(Melsheimer, Thomas)

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Datatreasury Corporation v. Wells Fargo & Company et al Doc. 348 Case 2:06-cv-00072-DF-CMC Document 348 Filed 11/08/2006 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION DATA TREASURY CORPORATION, Plaintiff v. WELLS FARGO & COMPANY; et al. Defendants JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER Defendants Bank of America, N.A. and Bank of America, Corp. jointly move with Plaintiff Data Treasury Corp. to extend the deadlines stated in the Court's Order from Scheduling Conference and Docket Control Order (Docket No. 325, and hereafter "Court's Order"). The Court's Order requires the parties to submit by November 8: (1) a proposed 2:06-CV-72 DF protective order, or separate proposals for protective order, (2) proposals for a "deposition protocol order," (3) candidates for special master, (4) candidates for technical advisor, and (5) notice regarding the parties' efforts to establish e-mail addresses for each litigant group. (Court's Order at 3, 6).1 Plaintiffs and all of the defendants2 continue to negotiate these issues so that as many issues as possible may be resolved and/or presented to the Court in joint submissions. The parties believe that an additional day to negotiate and finalize their submissions will result in fewer submissions and issues for the Court. Accordingly, the parties The deadline for filing the Agreed Motion for Entry of Protective Order or the parties separate proposals for protective orders is set by Docket No. 347. 2 Although Bank of America and Data Treasury jointly file this motion, all of the parties efforts to file joint submissions make this motion applicable to all parties. JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER - Page1 1 Dockets.Justia.com Case 2:06-cv-00072-DF-CMC Document 348 Filed 11/08/2006 Page 2 of 5 respectfully request that the Court extend the deadlines in the Court' s Order (Docket No. 325) from November 8, 2006 to November 9, 2006. JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER - Page2 Case 2:06-cv-00072-DF-CMC Document 348 Filed 11/08/2006 Page 3 of 5 Dated: November 8, 2006 Respectfully submitted, FISH & RICHARDSON P.C. By: /s Thomas M. Melsheimer Thomas M. Melsheimer Texas State Bar No. 13922550 1717 Main Street Suite 5000 Dallas, TX 75201 214-747-5070 (Telephone) 214-747-2091 (Telecopy) Robert E. Hillman Fish & Richardson P.C. 225 Franklin Street Boston, MA 02110-2804 617-542-5070 (Telephone) 617-542-8906 (Telecopy) Robert M. Parker Robert Christopher Bunt Parker & Bunt, P.C. 100 E. Ferguson, Suite 1114 Tyler, Texas 75702 (903) 531-3535 (Telephone) (903) 533-9687 (Telecopy) Michael E. Jones Texas Bar No. 10929400 E. Glenn Thames, Jr. Texas Bar No. 00785097 Potter Minton 500 Plaza Tower 110 North College, Suite 500 Tyler, TX 75702 Counsel for Defendants BANK OF AMERICA CORPORATION, BANK OF AMERICA, NATIONAL ASSOCIATION JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER - Page3 Case 2:06-cv-00072-DF-CMC Document 348 Filed 11/08/2006 Page 4 of 5 By: /s Karl Rupp With permission: R. Ritch Roberts Provost Umphrey Law Firm, LLP 3232 McKinney Ave., Suite 700 Dallas, TX 75204 214-744-3000 (Telephone) 214-744-3015 (Telecopy) Attorney for Plaintiff DATA TREASURY CORPORATION JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER - Page4 Case 2:06-cv-00072-DF-CMC Document 348 Filed 11/08/2006 Page 5 of 5 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served on November 8, 2006 to all counsel of record who are deemed to have consented to electronic service via the Court' s CM/ECF system per Local Rule CV-5(a)(3). /s Thomas M. Melsheimer Thomas M. Melsheimer 90198598.doc JOINT MOTION TO EXTEND DEADLINES SET FORTH IN ORDER FROM SCHEDULING CONFERENCE AND DOCKET CONTROL ORDER - Page5

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