Paid Search Engine Tools, LLC v. Google, Inc. et al

Filing 54

Agreed MOTION for Extension of Time to File (Agreed Motion to Extend Time to File Protective Order and Submit Mediator Names) by Paid Search Engine Tools, LLC. (Attachments: # 1 Text of Proposed Order)(Abernathy, Nancy)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PAID SEARCH ENGINE TOOLS, LLC, Plaintiff, vs. GOOGLE, INC. and MICROSOFT CORPORATION, Defendants. § § § § § § § § §

C.A. 2:08-cv-061 (DF/CE) Jury Demanded.

AGREED MOTION TO EXTEND TIME TO FILE PROTECTIVE ORDER AND SUBMIT MEDIATOR NAMES Now comes Plaintiff Paid Search Engine Tools, Inc. ("Plaintiff") and files this Agreed Motion to Extend Time to File Protective Order and Submit Mediator Names and would show the Court as follows: 1. The current deadline for the parties to file a Protective Order and to submit names for a mediator is January 15, 2009. 2. Plaintiff and Defendants seek an extension of time up to and including, February 5, 2009, to file a Protective Order and to submit names for a mediator. 3. This extension is not sought for delay, but only to give the parties more time to resolve their differences. 4. The parties contend that the requested extension will not delay or interfere with the management of the case or any other deadlines in this case.

Defendants Google Inc. and Microsoft Corporation ("Defendants") do not oppose this motion.

WHEREFORE, Plaintiff, Paid Search Engine Tools, LLC, respectfully prays that the Court grant this motion and permit an extension of time to file the Protective Order and submit mediator names up to and including February 5, 2009.

Dated: January 15, 2009 By:

Respectfully submitted, /s/ N. Claire Abernathy S. Calvin Capshaw State Bar No. 03783900 Email: [e-mail] Elizabeth L. DeRieux State Bar No. 05770585 Email: [e-mail] N. Claire Abernathy State Bar No. 24053063 Email: [e-mail] Capshaw DeRieux, LLP 1127 Judson Road, Suite 220 Longview, TX 75601 Telephone: [phone] Facsimile: [phone] Robert M. Parker State Bar No. 15498000 Email: [e-mail] Robert Christopher Bunt State Bar No. 00787165 Email: [e-mail] Charles Ainsworth State Bar No. 00783521 Email: [e-mail] Parker, Bunt & Ainsworth, P.C. 100 East Ferguson, Suite 1114 Tyler, Texas 75702 Telephone: [phone] Facsimile: [phone] J. Robert Chambers (Admitted pro hac vice) Email: [e-mail] Wood, Herron & Evans, L.L.P. -2-

2700 Carew Tower 441 Vine Street Cincinnati, Ohio 45202-2917 Telephone: [phone] Facsimile: [phone] Gregory M. Utter (Admitted pro hac vice) Email: [e-mail] W. Jeffrey Sefton (Admitted pro hac vice) Email: [e-mail] Keating, Muething & Klekamp, PLL One East Fourth Street, Suite 1400 Cincinnati, Ohio 45202 Telephone: [phone] Facsimile: [phone] Of Counsel: P. Andrew Blatt Email: [e-mail] John Paul Davis Email: [e-mail] Brett A. Schatz Email: [e-mail] Wood, Heron & Evans, L.L.P. 2700 Carew Tower 441 Vine Street Cincinnati, Ohio 45202-2917 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF, PAID SEARCH ENGINE TOOLS, LLC

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CERTIFICATE OF CONFERENCE I certify that I have complied with the meet and confer requirement in Local Rule CV7(H) and this motion is unopposed. /s/ N. Claire Abernathy CERTIFICATE OF SERVICE I hereby certify that all counsel of record who are deemed to have consented to electronic service are being served this 15th day of January, 2009, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ N. Claire Abernathy

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