ESN LLC v. Cisco Systems, Inc. et al

Filing 26

Joint MOTION for Extension of Time to File Motion for a Protective Order by Cisco Systems, Inc., Cisco-Linksys LLC. (Attachments: # 1 Text of Proposed Order)(Smith, Kevin)

ESN LLC v. Cisco Systems, Inc. et al

Doc. 26

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TEXARKANA DIVISION

ESN, LLC, Plaintiff, v. JURY TRIAL DEMANDED CISCO SYSTEMS, INC. and CISCO-LINKSYS LLC, Defendants. CIVIL ACTION NO. 5:08-CV-20

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A MOTION FOR A PROTECTIVE ORDER Defendants Cisco-Systems, Inc. and Cisco Systems, LLC respectfully move this Court for an extension of time to submit a motion for a protective order and state as follows: A Scheduling Conference in this case was held on April 22, 2008. The Court set a deadline of May 22, 2008 by which the parties were to submit to the Court an agreed Protective Order or, failing agreement, their respective proposals for a Protective Order in this case. The parties have met and conferred on numerous occasions regarding a Protective Order in this case and have agreed that the interest of justice would be served by an extension of the hereinbefore described deadline to and including May 28, 2008. This extension will not require an extension of any other deadlines set by the Court. This motion is not sought solely for the purpose of delay but so that justice may be done. The parties further request that, in the event

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that they are unable to reach agreement on a Protective Order, they each be permitted to submit their respective arguments. A proposed order accompanies this motion.

Dated: May 22, 2008

Respectfully submitted, By: /s/ Kevin A. Smith

MCKOOL SMITH P.C. SAM BAXTER Texas Bar No. 01938000 [e-mail] 104 E. Houston St., Suite 300 P.O. Box 0 Marshall, Texas 75670 Telephone : [phone] Facsimile : [phone] GARRET W. CHAMBERS Texas State Bar No. 00792160 [e-mail] 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone : [phone] Facsimile : [phone]

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QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP CHARLES K. VERHOEVEN LEAD COUNSEL Cal. Bar No. 170151 [e-mail] KATHERINE H. BENNETT [e-mail] Cal Bar. No. 250175 KEVIN A. SMITH Cal. Bar No. 250814 [e-mail] 50 California St., 22nd Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] VICTORIA F. MAROULIS Cal. Bar No. 202603 (admitted in E.D. Tex.) [e-mail] SAYURI K. SHARPER Cal. Bar No. 232331 [e-mail] 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 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 May 22, 2008. Any other counsel of record will be served by facsimile transmission and first class mail.

By:

/s/ Kevin A. Smith

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