Rockstar Consortium US LP et al v. Google Inc

Filing 65

Joint MOTION Joint Motion for Entry of Docket Control Order and Discovery Order and Notice of Compliance with Court Order by Google Inc, NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Exhibit A [Proposed] Docket Control Order, # 2 Exhibit B [Proposed] Discovery Order)(Lahad, John)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP AND
NETSTAR TECHNOLOGIES LLC
Case No. 2:13-cv-00893-JRG-RSP
Plaintiffs,
JURY TRIAL DEMANDED

v.
GOOGLE INC.
Defendant.

JOINT MOTION FOR ENTRY OF DOCKET CONTROL ORDER
AND DISCOVERY ORDER
AND NOTICE OF COMPLIANCE WITH COURT ORDER

On April 29, 2104, Plaintiffs Rockstar Consortium US LP and Netstar Technologies LLC
(“Plaintiffs”), and Defendant Google Inc. (“Google”) jointly submitted a proposed Docket
Control Order and Discovery Order. Docs. 57 and 58. At the time, the parties were not able to
agree on all aspects of the proposed Orders.
On May, 1, 2014, this Court denied the joint motions without prejudice and ordered “the
Parties to meet and confer in person with lead and local counsel on their remaining disputes in
the Docket Control and Discovery Orders and to file Proposed Docket Control and Discovery
Orders, certifying the results of such in-person meet and confer to the Court, within 7 days.”
Doc. 62.
The Parties certify that on May 8, 2014, lead and local counsel for Plaintiffs and
Defendant met and conferred in person in Houston, Texas and were able to reach agreement on
the remaining disputes in both Proposed Orders. Accordingly, the Parties jointly move for entry

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of their proposed Docket Control Order and Discovery Order, attached as Exhibit A and Exhibit
B, respectively.
DATED: May 8, 2014

Respectfully submitted,

/s/
John Lahad
Max L. Tribble, Jr. – Lead Counsel
State Bar No. 20213950
Alexander L. Kaplan, State Bar No. 24046185
John P. Lahad, State Bar No. 24068095
Shawn Blackburn, NY State Bar No. 5017249
SUSMAN GODFREY L.L.P.
1000 Louisiana Street, Suite 5100
Houston, Texas 77002
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Justin A. Nelson, State Bar No. 24034766
Parker C. Folse, III, WA State Bar No. 24895
Kristin Malone, WA State Bar No. 46251
SUSMAN GODFREY L.L.P.
1201 Third Ave, Suite 3800
Seattle, Washington 98101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
T. John Ward, Jr., State Bar No. 00794818
Claire Abernathy Henry, State Bar No. 24053063
WARD & SMITH LAW FIRM
P.O. Box 1231
Longview, TX 75606-1231
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
S. Calvin Capshaw, State Bar No. 03783900
Elizabeth L. DeRieux, State Bar No. 05770585
D. Jeffrey Rambin, State Bar No. 00791478
CAPSHAW DERIEUX, LLP
114 E. Commerce Ave.
Gladewater, TX 75647

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Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Rockstar Consortium US LP and
NetStar Technologies LLC

/s/ James Mark Mann
James Mark Mann
[e-mail]
Andy Tindel
[e-mail]
Gregory Blake Thompson
[e-mail]
Mann Tindel & Thompson
300 W. Main
Henderson, TX 75652
903-657-8540
Charles K. Verhoeven
[e-mail]
David A. Perlson
[e-mail]
Sean Pak
[e-mail]
Quinn Emanuel Urquhart & Sullivan
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6600
Robert Wilson
[e-mail]
Quinn Emanuel Urquhart & Sullivan
51 Madison Ave., 22nd Floor
New York, NY 10010
212-849-7145
Attorneys for Google Inc.

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CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to
electronic service are being served this 8th day of May, 2014 with a copy of this document via
the Court’s CM/ECF system per Local Rule CD-5(a)(3).

/s/

3159135v1/013149

John Lahad