Polaris IP, LLC v. Google Inc. et al

Filing 192

Agreed MOTION to Withdraw 185 SEALED MOTION To Quash And For Protective Order To Preclude Depositions of Google's High-Level Executives by Google Inc.. (Attachments: # 1 Text of Proposed Order)(Perlson, David)

Polaris IP, LLC v. Google Inc. et al

Doc. 192

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC v. GOOGLE INC., et al. NO. 2:07-CV-371-TJW-CE

AGREED MOTION TO WITHDRAW GOOGLE INC.'S MOTION TO QUASH AND FOR PROTECTIVE ORDER TO PRECLUDE DEPOSITIONS OF GOOGLE'S HIGHLEVEL EXECUTIVES

Whereas: 1. Google Inc. filed a Motion to Quash and for Protective Order to Preclude Depositions of Google's High Level Executives (Dkt. No. 185) on July 28, 2009. 2. Plaintiff Bright Response LLC has agreed to withdraw the deposition subpoenas to Google's executives without prejudice. The Parties jointly and respectfully move this Court for an Order withdrawing Google's Motion to Quash and for Protective Order without prejudice.

August 12, 2009

Respectfully submitted, By: /s/ David A. Perlson Charles K. Verhoeven, CA Bar No. 170151 LEAD ATTORNEY David A. Perlson, CA Bar No. 209502 Jennifer A. Kash, CA Bar No. 203679 Quinn Emanuel Urquhart Oliver & Hedges, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] [e-mail] 1
Dockets.Justia.com

[e-mail] [e-mail] [e-mail] Jennifer Parker Ainsworth TX Bar No. 00784720 Wilson, Robertson & Cornelius, P.C. P.O. Box 7339 Tyler, Texas 75711 Telephone: [phone] Facsimile: [phone] [e-mail] ATTORNEYS FOR GOOGLE INC.

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CERTIFICATE OF CONFERENCE The undersigned counsel for Google Inc. discussed this Motion with counsel for Plaintiff on August 12, 2009, and all parties agree to the Motion. /s/ David A.Perlson David A. Perlson

CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who are deemed to have consented to electronic service on the 12 of August, 2009. Local Rule CV-5(a)(3)(A). /s/ David A. Perlson________________ David A. Perlson