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

Filing 66

Joint MOTION for Entry of Discovery Order and Docket Control Order by Vertical Computer Systems Inc. (Attachments: # 1 Exhibit 1 - Proposed Discovery Order, # 2 Exhibit 2 - Proposed Docket Control Order)(Davis, William)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
VERTICAL COMPUTER SYSTEMS, INC.,
Plaintiff,
v.
INTERWOVEN, INC.,
LG ELECTRONICS MOBILECOMM
U.S.A., INC., LG ELECTRONICS
INC., SAMSUNG ELECTRONICS CO.,
LTD., SAMSUNG ELECTRONICS
AMERICA, INC.,
Defendants.

§
§
§
§ Civil Action No. 2:10-cv-490
§
§ JURY TRIAL DEMANDED
§
§
§
§
§
§
§
§

JOINT MOTION FOR ENTRY OF
DISCOVERY AND DOCKET CONTROL ORDERS
In accordance with the Court’s Order (Dkt. 55), the parties have met and conferred and
hereby submit their proposed Discovery and Docket Control Orders, attached hereto as Exhibits
1 and 2, respectively. The parties have no disagreements with respect to the proposed Docket
Control and Discovery Orders and respectfully request that they be entered by the Court.
Dated: November 2, 2011

Respectfully submitted,

By: /s/ David J. Healy
David J Healey
Texas State Bar No. 09327980
Fish & Richardson, PC
1221 McKinney Street, Suite 2800
Houston, Texas 77010
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

By: /s/ William E. Davis, III
William E. Davis, III
Texas State Bar No. 24047416
The Davis Firm, PC
111 West Tyler Street
Longview, Texas 75601
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Aamir A Kazi
Fish & Richardson PC
1180 Peachtree Street NE, 21st Floor

Vasilios D. Dossas
Illinois State Bar No. 6182616
Niro, Haller & Niro

Atlanta, Georgia 30309
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

181 West Madison Street, Suite 4600
Chicago, Illinois 60602
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Kevin Su
Fish & Richardson P.C.
One Marina Park Drive
Boston, MA 02210-1878
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorneys for Plaintiff,
Vertical Computer Systems, Inc.

Attorneys for Defendants,
LG Electronics Mobilecomm U.S.A., Inc
LG Electronics Inc.
By: /s/ Eric Hugh Findlay
Eric Hugh Findlay
Texas State Bar No. 00789886
Findlay Craft
6760 Old Jacksonville Hwy, Suite 101
Tyler, Texas 75703
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Jared B Bobrow
Weil Gotshal & Manges
201 Redwood Shores Parkway, 5th Floor
Redwood City, California 94065
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Julian Moore
Timothy E DeMasi
Weil Gotshal & Manges
767 Fifth Avenue
New York, NY 10153-0119
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendants,
2

Samsung Electronics Co., Ltd.
Samsung Electronics America, Inc.

3

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 2nd day of October, 2011.
/s/ William E. Davis, III
William E. Davis, III

4