PA Advisors, LLC v. Google Inc. et al

Filing 524

Unopposed MOTION for Extension of Time to File Response/Reply as to #493 SEALED MOTION Google's Motion for Determination of Exceptional Case and Award of Attorneys' Fees, #495 SEALED MOTION for Taxation of Costs by PA Advisors, LLC. (Attachments: #1 Text of Proposed Order)(Wiley, Elizabeth)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, v. GOOGLE INC., et al., Defendants. Civil Action No. 2:07-cv-480-RRR JURY TRIAL DEMANDED PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE SURREPLIES IN SUPPORT OF RESPONSE TO GOOGLE INC.'S MOTION FOR DETERMINATION OF EXCEPTIONAL CASE AND AWARD OF ATTORNEYS FEES (DKT. NO. 493) AND MOTION FOR TAXATION OF COSTS (DKT. NO. 495) Plaintiff PA Advisors, LLC, now known as nXn Tech, LLC ("nXn" or "Plaintiff"), respectfully files this motion for extension of time up to and including May 28, 2010 to file its surreply in support of its response to the motion of Google Inc. to declare this an exceptional case and award Google its attorneys' fees accordingly. Dkt. No. 493. This same request applies to a surreply in support of nXn's response to Google Inc.'s motion for taxation of costs (Dkt. No. 495). Plaintiff's current deadline for a surreply is May 21, 2010, and this request of a seven-day extension makes the new proposed deadline May 28, 2010. Google is not opposed to this extension of time. Plaintiff therefore respectfully requests that the Court extend the time for Plaintiff's surreplies to May 28, 2010. A proposed order to that effect is attached. Dated: May 12, 2010, Andrew W. Spangler SPANGLER LAW P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 (903) 753-9300 (903) 553-0403 (fax) spangler@spanglerlawpc.com David M. Pridham LAW OFFICE OF DAVID PRIDHAM 25 Linden Road Barrington, Rhode Island 02806 (401) 633-7247 (401) 633-7247 (fax) david@pridhamiplaw.com John M. Bustamante Texas Bar No. 24040618 BUSTAMANTE, P.C. 54 Rainey Street, No. 721 Austin, Texas 78701 Tel. 512.940.3753 Fax. 512.551.3773 Email:jmb@BustamanteLegal.com Respectfully submitted, By: /s/ Elizabeth A. Wiley_ Elizabeth A. Wiley Elizabeth A. Wiley Texas State Bar No. 00788666 THE WILEY FIRM PC P.O. Box. 303280 Austin, Texas 78703-3280 Telephone: (512) 560.3480 Facsimile: (512) 551.0028 Email: lizwiley@wileyfirmpc.com Marc A. Fenster CA Bar No. 181067 LEAD COUNSEL mfenster@raklaw.com Andrew Weiss CA Bar No. 232974 aweiss@raklaw.com Adam Hoffman CA Bar No. 218740 ahoffman@raklaw.com RUSS, AUGUST & KABAT 12424 Wilshire Blvd., 12th Floor Los Angeles, CA 90025 (310) 826-7474 (310) 826-6991 (fax) Patrick R. Anderson PATRICK R. ANDERSON PLLC 4225 Miller Rd, Bldg. B-9, Suite 358 Flint, MI 48507 (810) 275-0751 (248) 928-9239 (fax) patrick@prapllc.com 2 CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served on May 12, 2010 with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. \s\ Elizabeth A. Wiley Elizabeth A. Wiley 3

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