Polaris IP, LLC v. Google Inc. et al

Filing 247

Unopposed MOTION to Withdraw 244 SEALED MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND PRIVILEGE LOGS FROM PLAINTIFF AND ACCLAIM FINANCIAL GROUP LLC by AOL, LLC., America Online, Inc., Google Inc.. (Attachments: # 1 Text of Proposed Order)(Ainsworth, Jennifer)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC, Plaintiff, v. GOOGLE INC., ET AL., Defendants. § § § § § § § § § §

No. 2:07-cv-00371-CE Jury Demanded

UNOPPOSED MOTION OF DEFENDANT GOOGLE INC. TO WITHDRAW MOTION TO COMPEL WITHOUT PREJUDICE COMES NOW Defendant Google Inc. ("Google"), and files this motion to withdraw its currently pending motion to compel without prejudice, and would show the Court as follows: 1. On December 11, 2009, Google filed its Motion to Compel Production of

Documents and Privilege Logs from Plaintiff and Acclaim Financial Group, LLC (Dkt. #244). 2. Pursuant to the agreement reached with Plaintiff Bright Response with regard to

the documents and information sought from Plaintiff and Acclaim Financial Group, Google requests that its Motion to Compel Production of Documents and Privilege Logs from Plaintiff and Acclaim Financial Group, LLC (Dkt. #244) be withdrawn without prejudice to the re-filing of same. 3. This motion is not opposed by Plaintiff Bright Response.

Dated: December 23, 2009

Respectfully submitted, By: /s/ Jennifer Parker Ainsworth 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] Charles K. Verhoeven, CA Bar No. 170151 David A. Perlson, CA Bar No. 209502 LEAD ATTORNEY Jennifer A. Kash, CA Bar No. 203679 Rachel H. Smith, CA Bar No. 222075 Quinn Emanuel Urquhart Oliver & Hedges, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] ATTORNEYS FOR DEFENDANTS GOOGLE INC., AOL LLC, and AMERICA ONLINE, INC.

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 have consented to electronic service, Local Rule CV-5(a)(3)(A), on this the 23rd day of December, 2009. /s/ Jennifer P. Ainsworth_________ Jennifer P. Ainsworth

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CERTIFICATE OF CONFERENCE This is to certify that Jennifer P. Ainsworth conferred with counsel for plaintiff Bright Response on December 17, 2009 concerning this motion and counsel does not oppose the motion. _/s/ Jennifer P. Ainsworth____ Jennifer P. Ainsworth

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