Mirror Worlds, LLC v. Apple, Inc.

Filing 437

Joint MOTION for Extension of Time to File Response/Reply as to #415 MOTION to Seal Certain Trial Exhibits by Apple, Inc.. (Attachments: #1 Text of Proposed Order)(Randall, Jeffrey)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 437

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

MIRROR WORLDS, LLC, Plaintiff, 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 ADDITIONAL TIME FOR RESPONSE TO APPLE'S MOTION TO SEAL CERTAIN TRIAL EXHIBITS Mirror Worlds, LLC ("Mirror Worlds"), Mirror Worlds Technologies, Inc., and Apple Inc. ("Apple") (collectively, "the parties") respectfully submit this Joint Motion for Additional Time for Response to Apple's Motion to Seal Certain Trial Exhibits. The parties request a six-day extension until Wednesday, November 10, 2010 for Mirror Worlds to file its responsive brief. The additional time is sought to facilitate discussion of the issues raised in Apple's

JOINT MOTION FOR ADDITIONAL TIME FOR RESPONSE TO APPLE'S MOTION TO SEAL CERTAIN TRIAL EXHIBITS

-1-

CIVIL ACTION NO. 6:08-CV-88 LED
Dockets.Justia.com

motion and potentially narrow or resolve those issues. A proposed order is attached.

Dated: November 4, 2010 /s/ Alexander Solo Joseph Diamante Kenneth Stein Ian G. DiBernardo Alexander Solo STROOCK & STROOCK & LAVAN LLP 1280 Maiden Lane New York NY 10038 Telephone: [phone] Facsimile: 212-581-1071 [e-mail] Otis W. Carroll, Jr. ([e-mail]) Deborah J. Race ([e-mail]) IRELAND CARROLL & KELLEY 6101 S. Broadway, Suite 500 Tyler, TX 75730 Telephone: [phone] Facsimile: 903-581-1071 [e-mail] Attorneys for MIRROR WORLDS, LLC and MIRROR WORLDS TECHNOLOGIES, INC.

Respectfully submitted, /s/ Jeffrey G. Randall Jeffrey G. Randall Lead Attorney PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 1117 S. California Avenue Palo Alto, California 94304-1106 Telephone: [phone] Facsimile: [phone] [e-mail] Allan M. Soobert PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 875 15th Street, N.W. Washington, DC 20005 Telephone: [phone] Facsimile: [phone] [e-mail] S. Christian Platt PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 4747 Executive Dr., 12th Floor San Diego, CA 92121 Telephone: [phone] Facsimile: [phone] [e-mail]

JOINT MOTION FOR ADDITIONAL TIME FOR RESPONSE TO APPLE'S MOTION TO SEAL CERTAIN TRIAL EXHIBITS

-2-

CIVIL ACTION NO. 6:08-CV-88 LED

Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] [e-mail] Counsel for APPLE INC.

JOINT MOTION FOR ADDITIONAL TIME FOR RESPONSE TO APPLE'S MOTION TO SEAL CERTAIN TRIAL EXHIBITS

-3-

CIVIL ACTION NO. 6:08-CV-88 LED

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was filed electronically in compliance with Local Rule CV-5 on this 4th day of November, 2010. As of this date, all counsel of record had consented to electronic service and are being served with a copy of this document through the Court's CM/ECF system under Local Rule CV-5(a)(3)(A).

/s/ Jeffrey G. Randall Jeffrey G. Randall

JOINT MOTION FOR ADDITIONAL TIME FOR RESPONSE TO APPLE'S MOTION TO SEAL CERTAIN TRIAL EXHIBITS

-4-

CIVIL ACTION NO. 6:08-CV-88 LED