ESN LLC v. Cisco Systems, Inc. et al

Filing 189

Unopposed MOTION for Extension of Time to File Bill of Costs by Cisco Systems, Inc., Cisco-Linksys LLC. (Attachments: # 1 Text of Proposed Order)(Cannon, Matthew)

ESN LLC v. Cisco Systems, Inc. et al

Doc. 189

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TEXARKANA DIVISION ESN, LLC, Plaintiff, v. CISCO SYSTEMS, INC., and CISCO-LINKSYS, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 5:08-cv-20-DF JURY TRIAL DEMANDED

DEFENDANTS' SECOND UNOPPOSED MOTION TO EXTEND LOCAL RULE CV54(A) DEADLINE FOR FILING BILL OF COSTS Defendants Cisco Systems, Inc. and Cisco-Linksys, LLC move for an extension of five days in which to file their bill of costs pursuant to Local Rule CV-54. Pursuant to the Court's order granting Cisco's previous Unopposed Motion to Extend Local Rule CV-54(A) Deadline for Filing Bill of Costs (DN #187), the current deadline for Defendants to file their bill of costs is February 12, 2010. Because the parties are negotiating in good faith regarding Cisco's costs and believe they are near agreement, Cisco requests an additional extension of five days, until February 17, 2010, for the parties to continue attempting to resolve their dispute regarding Cisco's costs without the need for intervention by the Court. Plaintiff does not oppose this extension.

DATED: February 12, 2010

Respect fully submitted,

By /s/ Matthew D. Cannon

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POTTER MINTON A Professional Corporation MICHAEL JONES Tex. Bar No. 10929400 mikejo [e-mail] 110 N. College, Suite 500 (75702) P.O. Box 359 Tyler, Texas 75710 Telephone: [phone] Facsimile: [phone] QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP CHARLES K. VERHOEVEN LEAD COUNSEL Cal. Bar No. 170151 [e-mail] KEVIN A. SMITH Cal. Bar No. 250814 kevinsmit [e-mail] m MATTHEW D. CANNON Cal. Bar No. 252666 [e-mail] m 50 California St., 22nd Floor San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] VICTORIA F. MAROULIS Cal. Bar No. 202603 [e-mail] SAYURI K. SHARPER Cal. Bar No. 232331 [e-mail] m 555 Twin Dolphin Dr., Suite 560 Redwood Shores, California 94065 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Cisco Systems, Inc. and Cisco-Linksys, LLC

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CERTIFICATE OF SERVICE I hereby certify that on the date this proof of service is signed below, I served the foregoing: DEFENDANTS' SECOND UNOPPOSED MOTION TO EXTEND LOCAL RULE CV-54(A) DEADLINE FOR FILING BILL OF COSTS by email and via the Court's Electronic Filing System to George P. McAndrews [e-mail] Thomas J. Wimbiscus [e-mail] m Peter J. McAndrews [e-mail] Gerald C. Willis [e-mail] m Paul W. McAndrews [e-mail] m Matthew N. Allison [e-mail] m Heather Bjella [e-mail] m Holly Mack [e-mail] m McAndrews, Held & Malloy 500 West Madison, Suite 3400 Chicago, IL 60661 Telephone [phone] Fax [phone] Eric M. Albritton [e-mail] Albritton Law Firm P.O. Box 2649 Longview, Texas 75606 Telephone [phone] Fax [phone] T. John Ward [e-mail] m Ward & Smith Law Firm 111 West Tyler Street Longview, Texas 75601

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Telephone [phone] Fax [phone] Date: February 12, 2010 /s/ Matthew D. Cannon

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