Function Media, L.L.C. v. Google, Inc. et al

Filing 230

Joint MOTION for Extension of Time to File Pre-Trial Deadlines by Google, Inc.. (Attachments: # 1 Text of Proposed Order)(Candido, Amy)

Function Media, L.L.C. v. Google, Inc. et al

Doc. 230

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION FUNCTION MEDIA, L.L.C., v. JURY TRIAL DEMANDED GOOGLE, INC. AND YAHOO!, INC. JOINT MOTION TO EXTEND PRE-TRIAL DEADLINES In light of the Court's October 23, 2009 Notice of Hearing, Function Media and Google jointly move to extend certain pre-trial deadlines as follows: 1. Function Media and Google jointly move to extend the October 26, 2009 deadline for the parties' Responses to Motions in Limine, Responses to Dispositive Motions, Expert Witness designations and reports, and compliance with Local Patent Rule 3-7 to Tuesday, November 3, 2009. 2. Function Media and Google jointly move to extend the October 23, 2009 deadline to file their Joint Pretrial Order, Joint Proposed Jury Instructions and Form of the Verdict to December 3, 2009, which is more than one month before the January 4, 2010 date for jury selection. These extensions will not affect the pretrial conference, jury selection and trial dates set in the Court's October 23, 2009 Notice of Hearing. Civil Case No. 2:07-CV-279 (CE)

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Dockets.Justia.com

Dated: October 23, 2009

Respectfully submitted, QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP By: /s/ Amy H. Candido

Charles K. Verhoeven (admitted pro hac) Lead Attorney [e-mail] Amy H. Candido (admitted pro hac) [e-mail] Billie D. Salinas (admitted pro hac) [e-mail] Carl G. Anderson (admitted pro hac) [e-mail] QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Stan Karas (admitted pro hac) [e-mail] QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 865 S. Figueroa Street, 10th Floor Los Angeles, CA 90017 Telephone: [phone] Facsimile: [phone] Edward J. DeFranco (admitted pro hac) [e-mail] James M. Glass (admitted pro hac) [e-mail] Patrick Curran (admitted pro hac) [e-mail] QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 51 Madison Avenue, 22nd Floor New York, New York 10010 Telephone: [phone] Facsimile: [phone] Harry L. Gillam, Jr., Bar No. 07921800 [e-mail] Melissa R. Smith, Bar No. 24001351 [e-mail] GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, TX 75670 Telephone: [phone] Facsimile: [phone]
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Counsel for Defendant and Counter-Claimant Google Inc.

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CERTIFICATE OF CONFERENCE I hereby certify that counsel for Plaintiff, Joseph S. Grinstein has been contacted regarding the relief requested in this motion. Mr. Grinstein stated that Plaintiff was not opposed to the relief requested.

Dated: October 23, 2009

/s/ Amy H. Candido

CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served on October 23, 2009 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/ Amy H. Candido

01980.51542/3169080.1

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