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

Filing 133

Opposed 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

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Duvvuri, Raj

From:

Sent:
To: Cc:

Mark Baker (markbakercæquinnemanuel.com) Friday, February 27, 20093:38 PM

Kaplan, Lee
vhardycædpelaw. com; ccapshawcæcapshawlaw. com; rcbu ntcæpbatyler. com; charleycæpbatyler.com; Duvvuri, Raj; Jennifer A Kash; walshcæfr.com; rhungcæmofo.com; Saelao, Rebecca Snavely RE: Software Rights Archive, LLC--venue issue

Subject:
Lee:

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 courtesy to you and your trial schedule, we will agree to grant you until March 31 to file 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, 2ØØ9 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, 2ØØ9, 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, 2ØØ9 12: 29 PM To: Kaplan, Lee; walsh~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, 2ØØ9 11: 28 AM
To: i walsh~fr. com i; 'markbaker~quinnemanuel.. com'; i rhung~mofo. com i

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

i char ley~pbatyler. com i; Duvvuri, Raj

Subject: RE: Software Rights Archive, LLC- -venue issue

Mark, Tom, and Rich

Could y i all try to get back to me on this extension request today? I have to drive to
Marshall on Monday and won i t have time to spend on drafting the motion after the weekend.

Thx. Lee

- - - - -Original Message- - - -From: Kaplan, Lee Sent: Thursday, February 26, 2ØØ9 5: 19 PM
To: 'walsh~fr. com i; 'markbaker~quinnemanuel.. com' j i rhung~mofo. com i Cc: 'vhardy~dpelaw. com i; 'ccapshaw~capshawlaw. com i; 'rcbunt~pbatyler. com' ;

'charley~pbatyler. com'; Duvvuri, Raj Subject: Software Rights Archive, LLC- -venue issue
1

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 i t see how I could obtain discovery before the last half of April. Therefore I would appreciate your agreement to an extension of 6Ø 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

2

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