Albritton v. Cisco Systems, Inc. et al

Filing 168

Joint MOTION for Extension of Time to File Joint Pre-Trial Order by Eric Albritton. (Attachments: # 1 Text of Proposed Order)(Patton, Nicholas)

Albritton v. Cisco Systems, Inc. et al

Doc. 168

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION ERIC M. ALBRITTON, Plaintiff, v. (1) CISCO SYSTEMS, INC., (2) RICHARD FRENKEL, (3) MALLUN YEN and (4) JOHN NOH, Defendants. § § § § § § § § § § §

NO. 6:08-CV-00089

JOINT MOTION TO EXTEND THE DEADLINE FOR PLAINTIFF AND DEFENDANTS TO FILE JOINT PRE-TRIAL ORDER, EXHIBIT LISTS, PROPOSED JURY INSTRUCTIONS, AND DEPOSITION DESIGNATIONS COMES NOW Plaintiff and Defendants and for their Joint Motion, state: 1. The deadline for filing the Joint Pre-Trial Order, Exhibit Lists, Proposed Jury

Instructions and Video Deposition Designations set by this Court's Amended Scheduling Order (DE #32) is February 9, 2009. 2. The parties are in agreement and request that the Court grant them until February

16, 2009 to file the Joint Pre-Trial Order, Exhibit Lists, Proposed Jury Instructions and Video Deposition Designations. WHEREFORE, PREMISES CONSIDERED, the parties respectfully request that the Court grant this Joint Motion to Extend the Deadline for Plaintiff and Defendants to File Joint Pre-Trial Order, Exhibit Lists, Proposed Jury Instruction and Deposition Designations.

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Respectfully submitted, /s/ Nicholas H. Patton Nicholas H. Patton (TBN: 15631000) PATTON, TIDWELL & SCHROEDER, LLP 4605 Texas Boulevard ­ P.O. Box 5398 Texarkana, Texas 7550505398 [phone] [phone] (fax) Patricia L. Peden LAW OFFICE OF PATRICIA L. PEDEN 610 16th Street, Suite 400 Oakland, California 94612 Telephone: [phone] James A. Holmes Texas Bar No. 00784290 THE LAW OFFICE OF JAMES HOLMES, P.C. 635 South Main, Suite 203 Henderson, Texas 75654 903.657.2800 / 903.657.2855 (Fax) ATTORNEYS FOR PLAINTIFF /s/ Charles L. Babcock (with permission NHP) Charles L. Babcock Federal Bar No. 10982 Email: [e-mail] Crystal J. Parker Federal Bar No. 621142 Email: [e-mail] 1401 McKinney Suite 1900 Houston, Texas 77010 713.752.4200 713.752.4221 (Fax) /s/ George L. McWilliams (with permission NHP) George L. McWilliams GEORGE L. MCWILLIAMS, P.C. 406 Walnut ­ P.O. Box 58 Texarkana, Texas 75504-0058 903.277.0098 / 870.773.2937 (Fax) ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE I hereby 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 9th day of February, 2009. /s Nicholas H. Patton Nicholas H. Patton