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

Filing 259

Unopposed MOTION for Extension of Time to File Defendants' Unopposed Motion to Extend Certain Deadlines by Google Inc., AOL LLC. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Defendants' Motion to Extend Certain Deadlines)(O'Brien, Emily)

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Performance Pricing, Inc. v. Google Inc. et al Doc. 259 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PERFORMANCE PRICING, INC., Plaintiff, v. GOOGLE INC. and AOL LLC, Defendants. DEFENDANTS' UNOPPOSED MOTION TO EXTEND CERTAIN DEADLINES 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 certain deadlines in this matter. Defendant Google Inc.'s opposition to Plaintiff's Motion to Compel the Deposition of Michelle Lee is due Monday, November 30, 2009. Pursuant to the Court's Order issued on November 9, 2009, Daubert motions are due by November 24, 2009, and responses to such motions are due by December 22, 2009. Defendants respectfully request an extension of these deadlines as follows: Opposition to Motion to Compel Deposition of Michelle Lee extended until December 7, 2009. Daubert motion deadline extended until January 8, 2010. Daubert response deadline extended until January 22, 2010. The parties agreed to extend expert discovery until December 2009. This requested extension of Daubert deadlines would allow the parties to complete this discovery before filing their Daubert motions. Plaintiff has no opposition to Defendants' proposed extensions. JURY TRIAL DEMANDED Civil Action No. 2-07CV-432-LED (Eastern District of Texas) 01002.51305/3217020.1 WHEREFORE, Defendants respectfully request that the Court extend certain deadlines as outlined above. Defendants seek these extensions of time not for delay but for good cause and that justice may be served. DATED: November 24, 2009 /s/ Emily C. O'Brien Charles K. Verhoeven David A. Perlson Jennifer A. Kash Antonio R. Sistos Emily C. O'Brien QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Telephone: 415.875.6600 Facsimile: 415.875.6700 David J. Beck Texas Bar No. 00000070 Michael E. Richardson State Bar No. 24002838 Beck, Redden & Secrest, L.L.P. One Houston Center 1221 McKinney St., Suite 4500 Houston, TX. 77010 (713) 951-3700 (713) 951-3720 (Fax) Attorneys for Defendants GOOGLE INC. and AOL LLC 01002.51305/3217020.1 CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on November 24, 2009. /s Emily C. O'Brien Emily C. O'Brien, pro hac vice 01002.51305/3217020.1

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