Northeastern University et al v. Google, Inc.,

Filing 35

First MOTION for Extension of Time to File Mutually Agreeable Protective Order by Google, Inc.,. (Wolff, Jason) (Additional attachment(s) added on 8/27/2008: # 1 Text of Proposed Order) (sm, ).

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION NORTHEASTERN UNIVERSITY and JARG CORPORATION Plaintiffs, v. GOOGLE INC. Defendant. DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME FOR SUBMITTING MUTUALLY AGREEABLE PROTECTIVE ORDER Civil Action No. 2:07-CV-486-TJW-CE

Defendant Google Inc. ("Defendant") moves the Court for an unopposed extension of time to submit a proposed Docket Control Order and proposed Discovery Order to the Court. I. BRIEF BACKGROUND 1. On August 21, 2008, the Court signed and entered the parties' agreed-upon

Discovery Order. 2. Jury selection for this matter is currently scheduled for April 4, 2011. The claim

construction hearing is currently scheduled for October 6, 2010. 3. By Order signed August 21, 2008, (Dkt. No. 32), the Court ordered the parties to

submit a mutually agreeable protective order to the Court by August 26, 2008. II. RELIEF REQUESTED Defendant requests a two (2) day extension of time, until and including August 28, 2008, for the parties to confer and submit a mutually agreeable protective order to the Court. Jury selection is not scheduled until April 4, 2011, so there will be no adverse consequences to the

DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME FOR SUBMITTING PROPOSED DOCKET CONTROL ORDER AND DISCOVERY ORDER 1

Court's schedule by granting this brief extension. In addition, this motion is not opposed by Plaintiff. WHEREFORE, Defendant respectfully requests a two (2) day extension of time, until and including August 28, 2008, for the parties to confer and submit a mutually agreeable protective order to the Court.

DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME FOR SUBMITTING PROPOSED DOCKET CONTROL ORDER AND DISCOVERY ORDER 2

Dated: August 26, 2008

Respectfully submitted, FISH & RICHARDSON P.C.

By: Michael E. Jones (SBN 10929400) [e-mail] POTTER MINTON A Professional Corporation 110 N. College, Suite 500 Tyler, TX 75702 Telephone: [phone] Facsimile: [phone] Ruffin B. Cordell (SBN 04820550) [e-mail] FISH & RICHARDSON P.C. 1425 K Street, N.W., 11th Floor Washington, DC 20005-3500 Telephone: [phone] Facsimile: [phone] Howard G. Pollack (Admitted Pro Hac Vice) [e-mail] Shelley K. Mack (Admitted Pro Hac Vice) [e-mail] Jerry T. Yen (CA SBN 247988) [e-mail] FISH & RICHARDSON P.C. 500 Arguello Street, Suite 500 Redwood City, CA 94063 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant GOOGLE INC.

DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME FOR SUBMITTING PROPOSED DOCKET CONTROL ORDER AND DISCOVERY ORDER 3

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for the Plaintiff has been contacted regarding the relief requested in this motion and that Plaintiff has indicated that Plaintiff does not oppose the relief requested. /s/ Jason W. Wolff Jason W. Wolff

CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served on August 26, 2008 on all counsel of record who are deemed to have consented to electronic service via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Jason W. Wolff Jason W. Wolff

10863318.doc