Software Rights Archive, LLC v. Google Inc. et al

Filing 131

Unopposed MOTION for Extension of Time to File Response/Reply as to 130 SEALED MOTION Defendants' Motion to Transfer Pursuant to 28 U.S.C. 1404(a) SEALED MOTION Defendants' Motion to Transfer Pursuant to 28 U.S.C. 1404(a) SEALED MOTION Defendants' Motion to Transfer Pursuant to 28 U.S.C. 1404(a) by Software Rights Archive, LLC. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Kaplan, Lee)

EXHIBIT A

~Ian, Lee
From:

Sent:
To: Cc:

Subject:
Lee:

Mark Baker (markbaker~quinnemanuel.coml Friday, February 27, 2009 3:38 PM Kaplan, Lee vhardy~dpelaw.com; ccapshaw~capshawlaw.com; rcbunt~pbatyler.com; charley~pbatyler.com; Duvvuri, Raj; Jennifer A Kash; walsh~fr.com; rhung~mofo.com; Saelao, Rebecca Snavely RE: Software Rights Archive, LLC--venue issue

We have discussed your request for an extension. We do not believe any discovery is necessary in order for SRA to prepare its opposition to our transfer motion. However, as a we will agree to grant you until March 31 to file courtesy to you and your trial schedule, your opposition to our transfer motion. You may therefore list us as unopposed on a motion for an extension of time until and including March 31, 2009 for SRA to file its opposition to our transfer motion. However, in your certificate of conference, while you may state that you we do not oppose an extension until and including March 31, 2009, please do not state that we are in agreement that such an extension is necessary so that SRA can conduct discovery on the motion to transfer.

Best regards,
Mark

- - - - -Original Message- - - -From: Kaplan, Lee (mail to: LKaplan~SKV. com)

Sent: Friday, February 27, 2009 12: 29 PM To: Kaplan, Lee; waish~fr.com; Mark Baker; rhung~mofo.com Cc: vhardy~dpelaw. com; ccapshaw~capshawlaw. com; rcbunt~pbatyler. com; charley~pbatyler. com; Duvvuri, Raj Subject: RE: Software Rights Archive, LLC--venue issue

Resending since I again picked up the wrong address for Mark.

- - - - -Original Message- - - -From: Kaplan, Lee Sent: Friday, February 27, 2009 11: 28 AM
To: . walsh~r. com i; i markbaker~quinnemanuel. . com'; . rhung~mofo. com'

Cc: . vhardy~dpelaw. com'; . ccapshaw~capshawlaw. com'; · rcbunt~pbatyler. com' ;

. charley~pbatyler.com'; Duvvuri, Raj
Subject: RE: Software Rights Archive, LLC- -venue issue

Mark, Tom, and Rich Could y' all try to get back to me on this extension request today? I have to drive to Marshall on Monday and won' t have time to spend on drafting the motion after the weekend.

Thx. Lee

- - - - -Original Message- - - -From: Kaplan, Lee Sent: Thursday, February 26, 2009 5: 19 PM
To: · walsh~r. com'; · markbaker~quinnemanuel. . com'; i rhung~mofo. com i Cc: . vhardy&dpelaw. com i; . ccapshaw&capshawlaw. com i; . rcbunt~pbatyler. com' ; 'charley~pbatyler. com i; Duvvuri, Raj

Subject: Software Rights Archive, LLC--venue issue
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Tom, Mark and Rich-I will need discovery to respond to your motion to transfer. I also am deeply immersed in trial prep in another case (jury selection 3/3, additional hearing set 3/5 and the actual trial beginning 3/23). I don' t see how I could obtain discovery before the last half of April. Therefore I would appreciate your agreement to an extension of 60 days from the current response date (March 9) to May 8. Could u pIs let me know if Defts agree?

On another topic, any intelligence on the Delaware hearing date(s)?
Rgds. Lee

Sent from my BlackBerry Wireless Handheld

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