PA Advisors, LLC v. Google Inc. et al

Filing 296

Unopposed MOTION to Amend/Correct #186 Scheduling Order, by Google Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Text of Proposed Order)(Cannon, Brian)

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PA Advisors, LLC v. Google Inc. et al Doc. 296 UNTIED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, JURY TRIAL DEMANDED Honorable David Folsom, Presiding CASE NO. 2-07CV-480-DF GOOGLE INC., ET AL., Defendants. UNOPPOSED MOTION TO AMEND DOCKET CONTROL ORDER TO THE HONORABLE JUDGE OF THIS COURT: Defendant Google Inc. ("Google") on behalf of the parties in this action files this unopposed motion to amend the docket control order entered on August 25, 2008, to reflect the following changes: 1. This case is set for trial in March 2010. On September 30, 2009, this Court issued its claim construction order. The pretrial dates are set from the September 30, 2009 date. In order to provide sufficient time to complete pretrial tasks before March 2010, the parties agree to and propose modifications to the Docket Control Order set forth in redline in Exhibit A. Exhibit B contains a clean version of the Amended Docket Control Order. 2. In addition, in order to provide time to complete the disclosure of expert reports before filing any objections or Daubert motions related to proposed expert witness testimony, the parties request that the Court lift the requirement that the parties must seek permission to file Daubert motions 60 days before the deadline for dispositive motions. The 60 day requirement 1 would mean that letter briefs seeking permission to file Daubert motions would have been due before the disclosure of expert testimony. 3. The extension of these deadlines will not affect the date set for trial by this Court. Based on the foregoing, the parties respectfully request that the Court grant the requested extensions. DATED: November 4, 2009 Respectfully submitted, By: /s/ Brian C. Cannon Brian C. Cannon California Bar No. 193071 Quinn Emanuel Urquhart Oliver & Hedges, LLP 555 Twin Dolphin Drive, Suite 560 Redwood Shores, CA 94065 Tel.: (650) 801-5000 Fax: (650) 801-5100 Charles K. Verhoeven, California Bar No. 170151 Quinn Emanuel Urquhart Oliver & Hedges, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Tel.: (415) 875-6600 Fax: (415) 875-6700 Michael E. Richardson Texas Bar No. 24002838 BECK, REDDEN & SECREST, L.L.P. One Houston Center 1221 McKinney St., Suite 4500 Houston, Texas 77010 (713) 951-3700 (713) 951-3720 (Fax) 2 David J. Beck Texas Bar No. 00000070 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 GOOGLE INC. 3 CERTIFICATE OF CONFERENCE Counsel for Google discussed this Motion with counsel for Plaintiff and counsel for defendant Yahoo!, and all parties agree to the Motion. /s/ Brian C. Cannon Brian C. Cannon ___ CERTIFICATE OF SERVICE The undersigned 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 are deemed to have consented to electronic service as of the date of filing. Local Rule CV5(a)(3)(A). /s/ Brian C. Cannon Brian C. Cannon ___ 4

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