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)

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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 Dated: November 5,2009 Respectfully submitted, /s/ David J. Beck David J. Beck Texas Bar No. 00000070 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: (713) 951-3700 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: (415) 875 6600 Facsimile: (415) 875 6700 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

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