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

Filing 314

Unopposed MOTION for Extension of Time to File Opposition by Google Inc.. (Attachments: # 1 Text of Proposed Order)(O'Brien, Emily)

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

Doc. 314

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

PERFORMANCE PRICING, INC., Plaintiff, v. JURY TRIAL DEMANDED GOOGLE INC. AND AOL LLC, Defendants. Civil Action No. 2-07-CV-432-RRR (Eastern District of Texas)

GOOGLE INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR FILING OPPOSITION TO THE HONORABLE JUDGE OF THIS COURT: Defendant Google Inc. ("Google") files this Unopposed Motion for Extension of Time for Filing Opposition and respectfully ask the Court to extend a deadline in this matter. Google respectfully shows as follows: 1. Google's Opposition to Plaintiff's Motion to Compel 30(b)(6) Testimony is

currently due February 12, 2010. 2. Google seeks an extension of one week, until February 19, 2010, to file its

opposition brief. Plaintiff does not oppose this extension. 3. Google seeks this extension of time not for delay but for good cause and that

justice may be served. Google submits that the requested extension will not delay or interfere with the management of the case. WHEREFORE, Google respectfully requests that the Court grant this Unopposed Motion for Extension of Time for Filing Opposition and extend the deadline for filing an opposition to Plaintiff's Motion to Compel 30(b)(6) Testimony until February 19, 2010.

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Dated:

February 9, 2010

Respectfully submitted, By: /s/ Emily C. O'Brien Charles K. Verhoeven, pro hac vice [e-mail] Attorney In Charge David A. Perlson, pro hac vice [e-mail] Jamie L. Lisagor, pro hac vice [e-mail] Antonio R. Sistos, pro hac vice [e-mail] Emily C. O'Brien, pro hac vice [e-mail] Joshua L. Sohn, pro hac vice [e-mail] QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Michael E. Jones State Bar No. 10929400 Potter Minton, A Professional Corporation 110 North College, Suite 500 Tyler, Texas 75702 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Defendant Google Inc.

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CERTIFICATE OF SERVICE The undersigned hereby 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).

/s/ Emily C. O'Brien

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