Vertical Computer Systems, Inc. v. Interwoven, Inc. et al

Filing 64

Joint MOTION for Extension of Time to File Proposed Docket Control Order and Discovery Order by Vertical Computer Systems Inc. (Attachments: # 1 Text of Proposed Order)(Davis, William)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

VERTICAL COMPUTER SYSTEMS, INC.
Plaintiff,
v.

CIVIL ACTION NO. 2:10-CV-490-DF

LG ELECTRONICS MOBILECOMM U.S.A.,
INC., LG ELECTRONICS, INC., SAMSUNG
ELECTRONICS CO., LTD., SAMSUNG
ELECTRONICS AMERICA, INC.

JURY

Defendants.

JOINT MOTION FOR EXTENSION OF TIME TO
SUBMIT PROPOSED DOCKET AND DISCOVERY ORDERS
In Dkt. No. 63, the Court ordered the parties to submit their proposed docket control and
discovery orders by October 21, 2011. The parties have been conferring on the proposed docket
control and discovery orders but require more time to resolve their disputes.
Therefore, the parties jointly move for a short extension to November 2, 2011 to submit
their proposed docket control and discovery orders. The parties do not believe these extensions
will cause delay.

JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED DOCKET AND DISCOVERY
ORDERS - Page 1

Dated: October 21, 2011

Respectfully submitted,
THE DAVIS FIRM P.C.

By: /s/ William E. Davis, III
Vasilios D. Dossas ([e-mail])
Illinois State Bar No. 6182616
NIRO, HALLER & NIRO
181 West Madison Street, Suite 4600
Chicago, Illinois 60602
Telephone: [phone]
Fax: [phone]
William E. Davis, III
Texas State Bar No. 24047416
THE DAVIS FIRM, PC
111 West Tyler Street
Longview Texas 75601
Telephone: [phone]
Fax: [phone]

Counsel for Plaintiff
VERTICAL COMPUTER SYSTEMS, INC.

JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED DOCKET AND DISCOVERY
ORDERS - Page 2

By: /s/ Kevin Su (with permission)
David J. Healey
State Bar No. 09327980
Fish & Richardson P.C.
1221 McKinney, Suite 2800
Houston, TX 77010
713-654-5300 -- Telephone
713-652-0109 -- Facsimile
[e-mail]
Kevin Su
MA Bar No. 663726
Fish & Richardson P.C.
One Marina Park Drive
Boston, MA 02210-1878
617-542-5070 -- Telephone
617-542-8906 -- Facsimile
[e-mail]
OF COUNSEL:
Michael J. McKeon
Fish & Richardson P.C.
1425 K Street, NW, 11th Floor
Washington, DC 20005
202-783-5070 -- Telephone
202-783-2331 -- Facsimile
[e-mail]

Counsel for Defendants
LG ELECTRONICS MOBILECOMM
U.S.A., INC. AND LG ELECTRONICS,
INC.

JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED DOCKET AND DISCOVERY
ORDERS - Page 3

By: /s/ Julian Moore (with permission)
Eric H. Findlay
[e-mail]
State Bar No. 00789886
Brian Craft
[e-mail]
State Bar No. 04972020
FINDLAY CRAFT, LLP
6760 Old Jacksonville Highway, Suite 101
Tyler, TX 75703
Phone: [phone]
Fax: [phone]
Timothy DeMasi
[e-mail]
Julian Moore
[e-mail]
WEIL, GOTSHAL & MANGES LLP
767 5th Avenue
New York, NY 10153
Phone: [phone]
Fax: [phone]
Jared B. Bobrow
[e-mail]
WEIL, GOTSHAL & MANGES LLP
201 Redwood Shores Parkway
Redwood Shores, CA 94065
Phone: [phone]
Fax: [phone]

Counsel for Defendants
SAMSUNG ELECTRONICS CO., LTD.
SAMSUNG ELECTRONICS AMERICA,
INC.

JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED DOCKET AND DISCOVERY
ORDERS - Page 4

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, on this the 21st day of October, 2011.
/s/ William E. Davis, III
William E. Davis, III

JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED DOCKET AND DISCOVERY
ORDERS - Page 5