Rockstar Consortium US LP et al v. Google Inc

Filing 252

Unopposed MOTION for Hearing re 188 Appeal of Magistrate Judge Decision to District Court by Google Inc. (Attachments: # 1 Text of Proposed Order)(Perlson, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES LLC,
Plaintiffs,
v.
GOOGLE INC.
Defendant.

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Civil Action No. 13-cv-00893-JRG-RSP
JURY TRIAL DEMANDED

GOOGLE’S UNOPPOSED MOTION FOR HEARING ON ITS OBJECTIONS TO
ORDER DENYING MOTION TO TRANSFER (DKT. 188)
Defendant Google hereby respectfully moves, pursuant to Local Rule CV-7(g), to set
Google’s Objections to the Magistrate’s Memorandum Opinion and Order Denying Google’s
Motion to Transfer (Dkt. 188) for hearing on November 20, 2014. On November 3, 2014,
Magistrate Judge Payne set several matters for hearing on November 20, 2014, at 2:00 p.m.
(Dkt. 247.) Thus, the parties will already be appearing before Magistrate Judge Payne that same
day.
Google’s Objections are ripe for decision under Local Rule CV-7(f), and briefing on
Google’s Objections will be complete before November 20. Expedient resolution of Google’s
Objections will serve the interests of judicial economy and justice, including for the reasons set
forth in Google’s briefing on these motions, given the matters set for hearing on November 20,
and given the rapidly approaching remaining dates in the case schedule, including letter briefs on
dispositive motions (December 22, 2014), close of fact discovery (January 7, 2015), and opening
expert reports (January 19, 2015.) Lead and local counsel for the parties will be present at the

01980.00010/6313766.1

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November 20 hearing, and will be available to answer any questions that the Court may have on
Google’s Objections.
Plaintiffs have indicated they take no position on, and therefore do not object to,
Google’s request for a hearing on Google’s Objections.
Accordingly, Google requests that its motion be granted.

DATED: November 5, 2014

QUINN EMANUEL URQUHART & SULLIVAN, LLP
By

/s/ David Perlson
J. Mark Mann
State Bar No. 12926150
G. Blake Thompson
State Bar No. 24042033
MANN | TINDEL | THOMPSON
300 West Main Street
Henderson, Texas 75652
[phone]
[phone] (fax)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Charles K. Verhoeven
[e-mail]
David A. Perlson
[e-mail]
50 California Street, 22nd Floor
San Francisco, California 94111-4788
Telephone: [phone]
Facsimile: [phone]
Attorneys for Google Inc.

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CERTIFICATE OF CONFERENCE
I hereby certify that the parties met and conferred in writing pursuant to Local Rule CV7(h). On November 4, 2014, counsel for Rockstar (Justin Nelson) stated by email that Rockstar
takes no position on, and therefore does not object to, Google’s request for a hearing on Google’s
Objections.

/s/ David A. Perlson
David A. Perlson
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have
consented to electronic service are being served with a copy of this document via the Court’s
CM/ECF system per Local Rule CV-5(a)(3) on November 5, 2014.

/s/ Sam Stake
Sam Stake

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