Mirror Worlds, LLC v. Apple, Inc.

Filing 129

Joint MOTION for Extension of Time to File Mirror World's Response to Second Amended Answer and Counterclaims; and, Parties Deadline to Comply with Patent Local Rule 4-2, by Apple, Inc.. (Attachments: #1 Text of Proposed Order)(Smith, Stefani)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 129

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

JOINT MOTION FOR EXTENSION OF TIME Plaintiff and Counterclaim Defendant Mirror Worlds, LLC ("Mirror Worlds"), ThirdParty Defendant Mirror Worlds Technologies, Inc. ("MWT"), and Defendant and Counterclaim Plaintiff Apple Inc. ("Apple") hereby move to extend: (1) Mirror Worlds and MWT's deadline to answer or otherwise respond to Apple's Second Amended Answer, Affirmative Defenses and Counterclaims (D.E. 113) and (2) the parties' deadline to comply with Patent Local Rule 4-2, until Wednesday, September 30, 2009. Good cause exists for the requested relief. Mirror Worlds and MWT's present deadline to answer or otherwise respond to Apple's Second Amended Answer, Affirmative Defenses and Counterclaims is Friday, September 25.

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The parties respectfully request that the Court extend the time Mirror Worlds and MWT have to answer or otherwise respond to Wednesday, September 30. The parties' present deadline to comply with P.R. 4-2 is Wednesday, September 23, 2009. The parties respectfully request that the Court extend the time for the parties to comply with P.R. 4-2 to Wednesday, September 30. These extensions are 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 extend the deadlines as set forth herein above.

Dated: September 23, 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] 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 MIRROR WORLDS, LLC and MIRROR WORLDS TECHNOLOGIES, INC.

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] [e-mail] [e-mail] [e-mail] Attorneys for 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 23rd day of September, 2009. /s/ Stefani C. Smith Stefani C. Smith