AdvanceMe Inc v. AMERIMERCHANT LLC

Filing 135

Joint MOTION to Amend/Correct Docket Control Order of July 5, 2006 (Docket Entry 20) by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order Granting Joint Motion to Amend this Court's July 5, 2006 Docket Control Order)(Williams, Shanee)

AdvanceMe Inc v. AMERIMERCHANT LLC

Doc. 135

Case 6:06-cv-00082-LED-JDL

Document 135

Filed 06/05/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ADVANCEME, INC., Plaintiff, v. AMERIMERCHANT, LLC, Defendant. § § § § § § § CASE NO. 6:06-CV-082 (LED-JDL) § § § § § §

JOINT MOTION TO AMEND THIS COURT'S JULY 5, 2006 DOCKET CONTROL ORDER (DOCKET ENTRY 20)

TO THE HONORABLE JUDGE OF SAID COURT: Comes now, Plaintiff ADVANCEME, INC. and Defendant AMERIMERCHANT, LLC to bring this Joint Motion to amend the July 5, 2006 Docket Control Order (D.E. 20) as follows: CURRENT DEADLINE June 7, 2007 REQUESTED DEADLINE September 13, 2007 October 3, 2007 October 19, 2007 ACTION Parties with burden of proof designate expert witnesses (non-construction issues). Expert witness reports due. Refer to Local Rules for required information. Parties designate responsive expert witnesses (nonconstruction issues). Expert witness reports due. Refer to Local Rules for required information. Expert Witness Discovery Deadline.

June 18, 2007

There is not currently a separate deadline for the close of expert discovery. Pursuant to the Court's July 5, 2006 Docket Control Order, both fact and expert discovery close on July 17,
JOINT MOTION TO AMEND DOCKET CONTROL ORDER
LEGAL_US_W # 56404785.1 CASE NO.

6:06-CV-082 (LED-JDL)

Dockets.Justia.com

Case 6:06-cv-00082-LED-JDL

Document 135

Filed 06/05/2007

Page 2 of 3

2007. This Joint Motion does not request any amendment of the fact discovery cut-off; it only seeks to extend the expert disclosure deadlines and expert discovery cut-off as the parties agree that additional time is needed to complete the appropriate expert disclosures and expert discovery. Accordingly, the foregoing extensions are not sought for purposes of delay or any other improper purpose. Respectfully submitted,

Date: June 5, 2007

By: /s/ Shanée Y. Williams PAUL, HASTINGS, JANOFSKY & WALKER LLP Ronald S. Lemieux ([e-mail]) (CA Bar No. 120822) (Admitted Pro Hac Vice) Michael N. Edelman ([e-mail]) (CA Bar No. 180948) (Admitted Pro Hac vice) Vidya R. Bhakar ([e-mail]) (CA Bar No. 220210) (Admitted Pro Hac Vice) Robert C. Matz ([e-mail]) (CA Bar No. 217822) (Admitted Pro Hac Vice) Shanée Y. Williams ([e-mail]) (CA Bar No. 221310) (Admitted Pro Hac Vice) Five Palo Alto Square, Sixth Floor Palo Alto, CA 94306-2155 Telephone: [phone] Telecopier: [phone] IRELAND, CARROLL & KELLEY, P.C. Otis W. Carroll, Attorney-in-Charge State Bar No. 03895700 Deborah Race State Bar No. 16448700 6101 South Broadway, Suite 500 Tyler, TX 75703 Telephone: [phone] Facsimile: 903-581-1071 Email: [e-mail] ATTORNEYS FOR PLAINTIFF ADVANCEME, INC.

JOINT MOTION TO AMEND DOCKET CONTROL ORDER
LEGAL_US_W # 56404785.1

2

CASE NO.

6:06-CV-082 (LED-JDL)

Case 6:06-cv-00082-LED-JDL

Document 135

Filed 06/05/2007

Page 3 of 3

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Plaintiff met and conferred with Joseph Gray, counsel for Defendants, and Defendants agreed to join in this Joint Motion to Amend this Court's July 5, 2006 Docket Control Order (Docket Entry 20). /s/ Shanée Y. Williams Shanée Y. Williams

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). Any other counsel of record will be served by facsimile transmission and/or first class mail this 5th day of June, 2007. /s/ Shanée Y. Williams Shanée Y. Williams

JOINT MOTION TO AMEND DOCKET CONTROL ORDER
LEGAL_US_W # 56404785.1

3

CASE NO.

6:06-CV-082 (LED-JDL)