Rockstar Consortium US LP et al v. Google Inc
Filing
261
Unopposed MOTION for Extension of Time to File Replies in Support of Expedited Motions To Compel Discovery 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-RG
GOOGLE’S UNOPPOSED MOTION FOR EXTENSION OF TIME
FOR THE PARTIES TO FILE REPLIES IN SUPPORT OF
EXPEDITED MOTIONS TO COMPEL DISCOVERY
Defendant Google Inc. (“Google”) respectfully files this unopposed motion for extension
of time for the parties to file any replies in support of their expedited motions to compel
discovery. (Dkt. 222; Dkt. 245.) The parties filed their responses to the expedited motions on
November 5, 2014. (Dkts. 255-56.) The deadline for the parties to file any replies is November
10, and the deadline to file any sur-replies is November 17, 2014. (Dkt. 247.) The Court has set
a hearing on the expedited motions for November 20 at 2:00 PM.
Google respectfully requests a one-day extension of time for both parties, until November
11, 2014, to file any replies in support of the expedited motions to compel discovery. This
extension would provide the parties with an equal amount of time (6 days) to prepare both the
replies and sur-replies. This extension is not for the purpose of delay but rather so that the
parties may properly respond to response briefs. Google has conferred with Plaintiffs, who do
not oppose this motion.
01980.00010/6321371.1
1
DATED: November 7, 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
(903) 657-8540
(903) 657-6003 (fax)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
Charles K. Verhoeven
charlesverhoeven@quinnemanuel.com
David A. Perlson
davidperlson@quinnemanuel.com
50 California Street, 22nd Floor
San Francisco, California 94111-4788
Telephone: (415) 875 6600
Facsimile: (415) 875 6700
Attorneys for Google Inc.
01980.00010/6321371.1
2
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 7, 2014.
/s/ Sam Stake
Sam Stake
01980.00010/6321371.1
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