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

Filing 281

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

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Performance Pricing, Inc. v. Google Inc. et al Doc. 281 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 DEADLINES Defendants Google Inc. and AOL LLC respectfully file this Unopposed Motion seeking the extension of the summary judgment motion briefing schedule as follows: Regarding Plaintiff's Motions for Summary Judgment, filed November 23, 2009, Defendants' Oppositions would be due December 30, 2009, and Plaintiff's Replies would be due January 20, 2010. This extension would give the parties time to complete the necessary briefing, in particular due to the illness of one of the attorneys for Defendants. WHEREFORE, Defendants Google Inc., AOL LLC respectfully request that this Court extend the deadlines as outlined above. Defendants seek these extensions of time not for delay but for good cause and that justice may be served. JURY TRIAL DEMANDED Civil Action No. 2-07CV-432-RRR (Eastern District of Texas) DATED: December 28, 2009 /s/ Emily C. O'Brien Charles K. Verhoeven charlesverhoeven@quinnemanuel.com David A. Perlson davidperlson@quinnemanuel.com Jennifer A. Kash jenniferkash@quinnemanuel.com 01980.51426/3257877.1 Dockets.Justia.com Antonio R. Sistos antoniosistos@quinnemanuel.com Emily C. O'Brien emilyobrien@quinnemanuel.com QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Telephone: 415.875.6600 Facsimile: 415.875.6700 Michael E. Jones State Bar No. 10929400 Potter Minton, A Professional Corporation 110 North College, Suite 500 Tyler, Texas 75702 Telephone: (903) 597-8311 Facsimile: (903) 593-0846 mikejones@potterminton.com Attorneys for Defendants GOOGLE INC. and AOL LLC 01980.51426/3257877.1 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 December 28, 2009. /s Emily C. O'Brien Emily C. O'Brien, pro hac vice 01980.51426/3257877.1

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