Northeastern University et al v. Google, Inc.,

Filing 38

Joint MOTION For entry of protective order and for extension of time for submitting a mutually agreeable attachment to the protective order by Northeastern University, Jarg Corporation, Google, Inc.,. (Attachments: # 1 Exhibit A - Proposed Protective Order, # 2 Text of Proposed Order Granting extension of time)(Valek, Michael)

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Northeastern University et al v. Google, Inc., Doc. 38 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION ) NORTHEASTERN UNIVERSITY and JARG ) CORPORATION, ) Civil Action No. 2:07-cv-486-CE Plaintiffs, ) ) v. ) JURY TRIAL DEMANDED ) GOOGLE INC., ) Defendant. ) ) ) ) JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER AND TO EXTEND TIME FOR SUBMITTING A MUTUALLY AGREEABLE ATTACHMENT TO THE PROTECTIVE ORDER I. INTRODUCTION Plaintiffs Northeastern University and Jarg Corporation and Defendant Google, Inc. have agreed to the provisions of the Proposed Protective Order ("Protective Order") attached as Exhibit A. The parties jointly move the court for entry of the agreed upon Protective Order. The Protective Order refers to an Attachment A intended to be executed by consultants retained by the parties for this litigation. The parties jointly request additional time to confer and submit a mutually agreeable Attachment A to the Protective Order. II. 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 27, 2008, (Dkt. No. 37), the Court ordered the parties to submit a mutually agreeable protective order to the Court by August 28, 2008. 4. The parties have agreed upon the Protective Order attached as Exhibit A. III. RELIEF REQUESTED 1. The parties jointly request that the Court sign and enter the Protective Order attached as Exhibit A. 2. The parties jointly request a two day extension of time, until and including Tuesday, September 2, 2008, for the parties to confer and submit a mutually agreeable attachment to the Protective Order. Jury selection is not scheduled until April 4, 2011, so there will be no adverse consequences to the Court's schedule by granting this brief extension. In addition, this motion is not opposed by Defendant. WHEREFORE, the parties respectfully request (a) entry of the Protective Order attached as Exhibit A and (b) a two day extension of time, until and including Tuesday, September 2, 2008 for the parties to confer and submit a mutually agreeable attachment to the Protective Order to the Court. Dated: August 28, 2008 Respectfully submitted, /s/ Michael Valek William B. Dawson (Tx Bar No. 05603600) VINSON & ELKINS L.L.P. 3700 Trammel Crow Center 3001 Ross Avenue Dallas, Texas 75201-2975 Tel: (214) 220-7926 Fax: (214) 999-7926 David B. Weaver (TX Bar No. 00798576) Christopher V. Ryan (TX Bar No. 24037412) Michael Valek (TX Bar No.24044028) R. Floyd Walker (TX Bar No. 24044751) Stephen C. Stout (TX Bar No. 24060672) VINSON & ELKINS L.L.P. 2801 Via Fortuna, Suite 100 Austin, Texas 78746 Tel: (512) 542-8400 Fax: (512) 236-3338 Otis W Carroll, Jr. Collin Maloney IRELAND CARROLL & KELLEY 6101 S Broadway, Suite 500 Tyler, TX 75703 Tel: 903-561-1600 Fax: 903-581-1071 Franklin Jones, Jr. JONES & JONES, INC. P.C. 201 W Houston St., PO Drawer 1249 Marshall, TX 75671-1249 Tel: 903-938-4395 Fax: 903-938-3360 ATTORNEYS FOR PLAINTIFFS NORTHEASTERN UNIVERSITY AND JARG CORPORATION /s/ Jason W. Wolff (with permission) Michael E. Jones (SBN 10929400) POTTER MINTON A Professional Corporation 110 N. College, Suite 500 Tyler, TX 75702 Telephone: (903) 597-8311 Facsimile: (903) 593-0846 Ruffin B. Cordell (SBN 04820550) FISH & RICHARDSON P.C. 1425 K Street, N.W., 11th Floor Washington, DC 20005-3500 Telephone: (202) 783-5070 Facsimile: (202) 783-2331 Howard G. Pollack (Admitted Pro Hac Vice) Shelley K. Mack (Admitted Pro Hac Vice) Jerry T. Yen (CA SBN 247988) FISH & RICHARDSON P.C. 500 Arguello Street, Suite 500 Redwood City, CA 94063 Telephone: (650) 839-5070 Facsimile: (650) 839-5071 Jason W. Wolff (Admitted Pro Hac Vice) FISH & RICHARDSON P.C. 12390 El Camino Real San Diego, CA 92130 Telephone: (858) 678-5070 Facsimile: (858) 678-5099 ATTORNEYS FOR DEFENDANT GOOGLE INC. CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), 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 email and/or fax, on this the 28th day of August, 2008. /s/ Michael A. Valek

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