Rockstar Consortium US LP et al v. Google Inc

Filing 25

Unopposed MOTION for Extension of Time to File Response/Reply as to 18 MOTION to Change Venue by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Text of Proposed Order)(Nelson, Justin)

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

ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,
Civil Action No. 2:13-cv-893

Plaintiff,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

ROCKSTAR CONSORTIUM US LP AND NETSTAR TECHNOLOGIES LLC’S
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPPOSITION TO
GOOGLE INC.’S MOTION TO TRANSFER VENUE
Plaintiffs Rockstar Consortium US LP and NetStar Technologies LLC file this
unopposed motion for an extension of time to file their opposition to Defendant Google Inc.’s
motion to transfer venue up to and including February 20, 2014. Plaintiffs have conferred with
Defendant, who does not oppose this motion. This extension is not for the purpose of delay but
rather to properly respond to Google’s motion.
DATED: January 17, 2014

Respectfully submitted
By: /s/ Justin A. Nelson
Max L. Tribble, Jr. – Lead Counsel
State Bar No. 20213950
Alexander L. Kaplan
State Bar No. 24046185
John P. Lahad
State Bar No. 24068095
SUSMAN GODFREY L.L.P.
1000 Louisiana Street, Suite 5100
Houston, Texas 77002
Telephone: [phone]
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Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Justin A. Nelson, State Bar No. 24034766
Parker C. Folse, III, WA State Bar No. 24895
SUSMAN GODFREY L.L.P.
1201 Third Ave, Suite 3800
Seattle, Washington 98101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
T. John Ward, Jr., State Bar No. 00794818
WARD & SMITH LAW FIRM
P.O. Box 1231
Longview, TX 75606-1231
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Rockstar Consortium US LP and
NetStar Technologies LLC

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CERTIFICATE OF CONFERENCE
I hereby certify that counsel for Rockstar Consortium US LP and NetStar Technologies
LLC conferred with counsel for Defendant on January 16, 2014. Counsel for Defendant agreed
to the extension requested in this motion.
/s/ Justin A. Nelson

CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to
electronic service are being served this 17th day of January, 2014 with a copy of this document
via the Court’s CM/ECF system per Local Rule CD-5(a)(3).
/s/ Justin A. Nelson

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