PA Advisors, LLC v. Google Inc. et al

Filing 488

Unopposed MOTION for Extension of Time to File Bill of Costs and Motions for Exceptional Case, Attorney's Fees and Costs by Google Inc., Yahoo! Inc.. (Attachments: #1 Text of Proposed Order)(Doan, Jennifer)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, CASE NO. 2-07-CV-480-RRR GOOGLE INC., ET AL., Defendants. DEFENDANTS' UNOPPOSED MOTION TO EXTEND TIME FOR FILING BILL OF COSTS AND MOTIONS FOR EXCEPTIONAL CASE, ATTORNEY'S FEES AND COSTS Defendants Yahoo! Inc. and Google, Inc. ("Defendants") move the Court to enlarge the time within which Defendants are required to file their bill of costs and motions for exceptional case, attorney's fees and costs. Defendants' bill of costs and motions for exceptional case, attorney's fees and costs are currently due March 30, 2010. However, the parties have not been able to meet and confer on these issues due to an upcoming Markman hearing in another matter. As such, Plaintiff's counsel has agreed to allow Defendants an extension until and including April 2, 2010, to file their motions in order to facilitate time for a meaningful meet and confer to determine whether some of these issues can be resolved without Court intervention. The parties anticipate that this meet and confer can happen in the next three days. Therefore, good cause exists for this Court to grant this unopposed motion. For all these reasons, Defendants respectfully request an extension of time of three days, or until and including April 2, 2010, to file their bill of costs and motions for exceptional case, attorney fees and costs. DEFENDANTS' UNOPPOSED MOTION TO EXTEND TIME Page 1 Respectfully submitted, /s/ Jennifer H. Doan Jennifer H. Doan Texas Bar No. 08809050 John Scott Andrews Texas Bar No. 24064823 HALTOM & DOAN 6500 Summerhill Road, Suite 100 Texarkana, Texas 75503 Tel: 903.255.1002 Fax: 903.255.0800 Email: jdoan@haltomdoan.com Email: sandrews@haltomdoan.com William Rooklidge HOWREY LLP 4 Park Plaza, Suite 1700 Irvine, CA 92614-8557 Tel: 949-721-6900 Email: rooklidgew@howrey.com Jason C. White HOWREY LLP 321 N. Clark, Suite 3400 Chicago, IL 60654 Tel: 312.595.1239 Fax: 312.595.2250 Email: whitej@howrey.com Attorneys for Defendant Yahoo! Inc. /s/ David A. Perlson (with permission) Charles K. Verhoeven Email: charlesverhoeven@quinnemanuel.com State Bar No. 170151 David A. Perlson Email: davidperlson@quinnemanuel.com State Bar No. 209502 Quinn Emanuel Urquhart Oliver & Hedges LLP 50 California St. San Francisco, CA 94111 Telephone: (415) 875-6600 DEFENDANTS' UNOPPOSED MOTION TO EXTEND TIME Page 2 Brian C. Cannon Email: briancannon@quinnemanuel.com State Bar No. 193071 Andrea Pallios Roberts Email: andreaproberts@quinnemanuel.com State Bar No. 228128 Quinn Emanuel Urquhart Oliver & Hedges LLP 555 Twin Dolphin Dr. Ste. 560 Redwood Shores, CA 94065 Telephone: (650) 801-5000 Harry L. Gillam, Jr. State Bar No. 07921800 Email: gil@gillamsmithlaw.com Melissa R. Smith State Bar No. 24001351 Email: melissa@gillamsmithlaw.com GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, TX 75670 Telephone: (903) 934-8450 Counsel for Google Inc. CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). All other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by certified mail, return receipt requested, on this the 30th day of March, 2010. /s/ Jennifer H. Doan Jennifer H. Doan DEFENDANTS' UNOPPOSED MOTION TO EXTEND TIME Page 3

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