Mirror Worlds, LLC v. Apple, Inc.

Filing 118

Joint MOTION for Extension of Time to File for the Parties to Comply with P.R. 4-3 by Apple, Inc.. (Attachments: #1 Text of Proposed Order)(Smith, Stefani)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 118

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaint iff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED

JOINT MOTION FOR AN EXTENSION OF TIME FOR THE PARTIES TO COMPLY WITH P.R. 4-3 Plaint iff and Counterclaim Defendant Mirror Worlds, LLC ("Mirror Worlds") and Defendant and Counterclaim Plaintiff Apple Inc. ("Apple") hereby move to extend the parties' deadline to comply with Patent Local Rule 4-3 until Friday, October 30, 2009. Good cause exists for the requested relief. The parties' present deadline to comply with Patent Local Rule 4-3 is Friday, October 23, 2009. The parties have scheduled a mediation starting Wednesday, October 21, 2009.

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Accordingly, the parties respectfully request the Court to extend the time to comply with Patent Local Rule 4-3 to Friday, October 30, 2009. This extension is not sought for the purpose of delay, but instead so that justice may be served. WHEREFORE, PREMISES CONSIDERED, the parties respectfully request the Court to grant their motion to permit Apple to file its opposition as set forth herein above.

Dated: September 8, 2009 /s/ Richard An Otis Carroll Texas Bar No. 03895700 Lead Attorney Deborah Race Texas Bar No. 16448700 IRELAND, CARROLL & KELLY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 903-561-1600 (Telephone) 903-581-1071 (Facsimile) [e-mail] m Of counsel: Joseph Diamante (Pro Hac Vice) Kenneth Stein (Pro Hac Vice) Richard An (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, NY 10038 212-806-5400 (Telephone) 212-806-6006 (Facsimile) [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff MIRROR WORLDS, LLC

Respectfully submitted, /s/ Stefani C. Smith Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 [phone] (Telephone) [phone] (Facsimile) [e-mail] Matthew Powers Lead Attorney Steven S. Cherensky Sonal N. Mehta (Pro Hac Vice) Stefani C. Smith (Pro Hac Vice) WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (Telephone) 650-802-3100 (Facsimile) [e-mail] m [e-mail] m [e-mail] m stefani.smit [e-mail] m Attorneys for Defendant APPLE INC.

CERTIFICATE OF SERVICE This is to certify 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 this the 8th day of September, 2009. /s/ Stefani C. Smith Stefani C. Smith