Performance Pricing, Inc. v. Google Inc. et al

Filing 244

Unopposed MOTION for Extension of Time to File Defendants' Unopposed Motion to Extend Deadlines for Daubert Motions and Responses by AOL LLC, Google Inc.. (Attachments: # 1 Text of Proposed Order)(Beck, David)

Performance Pricing, Inc. v. Google Inc. et al

Doc. 244

TINITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

PERFORMANCE PRICING, INC.,

PIaintifl
v.

Civil Action No. 2-07CV-432-LED (Eastern District of Texas)

GOOGLE INC. and AOL LLC,
Defendants.

J[]RY TRIAL DEMANDED

DEFENDANTS'TINOPPOSED MOTION TO EXTEI\D DEADLINES FOR DATTBERT MOTIONS Ai\D RESPONSES
TO THE HONORABLE JUDGE OF THIS COURT:
Defendants Google Inc. and AOL LLC ("Defendants") file this unopposed motion and

respectfully ask the Court to extend the deadline for Daubert motions and responses in this

matter. Pursuant to the Court's Docket Control Order issued on June 22,2009, Daubert motions
are due by November 20,2009, and responses to such motions are due by December 18, 2009.

Defendants respectfully request an extension of the Daubert motion deadline until November 24,

2009. This brief extension would give Defendants adequate time to review the depositions of

Plaintiff s experts and, as appropriate, to use these depositions in support of its Dauberl motions.
In order to accommodate this four-day proposed extension for Daubert motions, Defendants also
respectfully request that the deadline for Daubert responses be extended by four days as well,

until December 22,2009. Defendants have notified Plaintiff of these requests, and Plaintiffhas
no opposition to Defendants' proposed extensions.

WHEREFORE, Defendants respectfully request that the Court extend the deadline for Daubert motions and responses as outlined above.

0l 002.5 I 305/3 I 87534. I

Dockets.Justia.com

Dated: November

5,2009

Respectfully submitted,
/s/ David J. Beck David J. Beck Texas Bar No. 00000070 [e-mail] Becr, RepoeN & Secnpsr, L.L.P. One Houston Center I22l McKinney St., Suite 4500 Houston, Texas 77010 (713) 9sr-3700 (713) 9sI-3720 (Fax)

By:

LB.lo ArronNBv FoR DEFENDANT Goocln INc.
OF COTINSEL:

Michael E. Richardson State Bar No. 24002838
mri chard s o n @b rs firm. co m BECK, ReooeN & Spcnesr, L.L.P. One Houston Center I22l McKinney St., Suite 4500 Houston, Texas 77010 Telephone: [phone] Facsimile: (7 13) 951-3720

Charles K. Verhoeven (admitted pro hac vice) charlesverho even@quinnemanuel. com David A. Perlson (admittedpro hac vice) davidperl son@quinnemanuel. com Antonio R. Sistos (admittedpro hac vice) antoniosisto s@quinnemanuel. com Emily C. O'Brien (admittedpro hac vice) emilyobrien@quinnemanuel. com

QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22ndFloor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone]

l 167.0000r/436250.1

CERTIFICATE OF SERVICE
The undersigned hereby certifies that the foregoing document was f,iled 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).
/s/ Michael E. Richardson Michael E. Richardson

tt6't .0000U436250.t