Northeastern University et al v. Google, Inc.,

Filing 41

Joint MOTION to Enter Protective Order re 38 Joint MOTION For entry of protective order and for extension of time for submitting a mutually agreeable attachment to the protective order - This motion supercedes 38 in that the previously proposed Agreed Protective Order has not been entered and the attached proposed Agreed Protective Order includes both the Protective Order and the mutually agreeable attachment by Northeastern University, Jarg Corporation, Google, Inc.,. (Attachments: # 1 Text of Proposed Order)(Valek, Michael) (Additional attachment(s) added on 9/3/2008: # 2 Revised Order) (sm, ).

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Northeastern University et al v. Google, Inc., Doc. 41 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 TO ENTER PROTECTIVE ORDER Come now Plaintiffs Northeastern University and Jarg Corporation and Defendant Google, Inc. and file this Joint Motion to Enter Protective Order, and in support of same would show the Court as follows: I. An agreed upon protective order was filed with the Court by joint motion on August 28, 2008 (Docket No. 38). II. The current deadline to submit an attachment to the agreed protective order in this case is September 2, 2008. III. The Parties have conferred and have reached agreement on the form of the attachment to the agreed protective order. Together, the Parties now move the Court for entry of the Agreed Protective Order together with the attachment, submitted herewith as Exhibit A. For the convenience of the Court, Exhibit A includes both the Agreed Protective Order, previously filed with the Court, and the attachment. Dated: September 2, 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 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 2nd day of September, 2008. /s/ Michael A. Valek

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