Rockstar Consortium US LP et al v. Google Inc

Filing 84

Joint MOTION for Extension of Time to File a Proposed E-Discovery Order by Google Inc, NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Text of Proposed Order)(Blackburn, Shawn)

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

Plaintiffs,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

JOINT MOTION FOR EXTENSION OF TIME
TO FILE A PROPOSED E-DISCOVERY ORDER
Plaintiffs Rockstar Consortium US LP and Netstar Technologies LLC (“Plaintiffs”), and
Defendant Google Inc. (“Google”) respectfully submit this Joint Motion for an Extension of
Time to File a Proposed E-Discovery Order.
The original deadline for the parties to submit a Proposed E-Discovery Order was
May 28, 2014. On May 30, 2014, the Court granted a Joint Motion for an Extension of Time to
File a Proposed E-Discovery Order. On June 11, 2014, the Parties jointly requested an extension
of time for the parties to jointly submit a Proposed E-Discovery Order by two days, from June
11, 2014 to June 13, 2014. Finally, the Court granted the parties an additional extension until
June 16, 2014. With this motion, the Parties jointly and respectfully request an extension of time
for the parties to jointly submit a Proposed E-Discovery Order, from June 16, 2014 to June 17,
2014. The request is supported by good cause because the parties have been discussing each
other’s proposals with respect to the E-Discovery Order throughout the day today, with the hope
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of resolving final disputes and narrowing the issues that may need to be presented to the Court.
With these final negotiations, the parties have narrowed their disputes and have put the proposed
order in condition for submission to the Court with as few disputed issues as possible. This final
one-day extension will allow the parties time to prepare a joint motion with its attendant briefs
for submission to the Court tomorrow. A proposed order granting the requested relief is filed
concurrently herewith.
DATED: June 16, 2014
Respectfully submitted,
/s/

Shawn D. Blackburn

/s/ David A. Perlson

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]

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

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]
3211498v1/013643

Robert Wilson
[e-mail]
2

[e-mail]
[e-mail]

Quinn Emanuel Urquhart & Sullivan
51 Madison Ave., 22nd Floor
New York, NY 10010
212-849-7145

T. John Ward, Jr., State Bar No. 00794818
Claire Abernathy Henry, ST. Bar No. 24053063
WARD & SMITH LAW FIRM
P.O. Box 1231
Longview, TX 75606-1231
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Andrea Pallios Roberts
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
555 Twin Dolphin Dr., 5th Floor
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR DEFENDANT
GOOGLE INC.

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
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

ATTORNEYS FOR PLAINTIFFS
ROCKSTAR CONSORTIUM US LP AND
NETSTAR TECHNOLOGIES LLC

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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 16th day of June, 2014 with a copy of this document via
the Court’s CM/ECF system per Local Rule CD-5(a)(3).

/s/ Shawn D. Blackburn
Shawn D. Blackburn

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