Albritton v. Cisco Systems, Inc. et al

Filing 269

Agreed MOTION for Extension of Time to File Revised Pretrial Order by Eric Albritton, Cisco Systems, Inc., Richard Frenkel. (Attachments: # 1 Agreed Order)(Babcock, Charles)

Albritton v. Cisco Systems, Inc. et al Doc. 269

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ERIC ALBRITTON, Plaintiff CIVIL ACTION NO.: 6:08-CV-89 V. CISCO SYSTEMS, INC., and RICK FRENKEL, Defendants JURY TRIAL DEMANDED

AGREED MOTION TO EXTEND THE FILING OF A REVISED PRETRIAL ORDER TO THE HONORABLE UNITED STATES DISTRICT JUDGE: Plaintiff ERIC ALBRITTON and Defendants CISCO SYSTEMS, INC. AND RICHARD FRENKEL request the Court to modify the deadline in the Court's June 5, 2009 Order. On June 5 th the Court ordered that the parties undertake a good faith effort to do the following by July 5, 2009: 1. Reduce the number of exhibits and deposition excerpts that will be offered at trial.

2, Reduce the number of objections to the remaining exhibits and deposition excerpts that will be offered at trial. The Court also ordered the parties to provide by July 5, 2009, a revised joint final pretrial order that would conform to the Court's various rulings in this matter. As part of the revised joint final pretrial order, the parties are to reduce the number of, and objections to, exhibits and deposition excerpts. The parties would jointly request that the court extend the July 5, 2009 deadline to August 14, 2009. This extension is requested due to unforeseen events that have affected Plaintiff s counsel's ability to confer on the various issues prior to the July 5 date. The parties are cooperatively working to comply with the Court's order.
AGREED MOTION TO EXTEND THE DISCOVERY AND MOTION FOR SUMMARY JUDGMENT DEADLINES -Page 1-

Dockets.Justia.com

The parties have been diligently working to revise their exhibits and deposition designations and do anticipate being able to reduce the number of exhibits and deposition designations to be offered at trial and to revise the pretrial order. Respectfully submitted,
PATTON, TIDWELL & SCHROEDER, L.L.P.

/s/ Nicholas H. Patton By: by permission Charles L. Babcock Nicholas H. Patton Texas Bar No.: 15631000 Email: [e-mail] 4605 Texas Blvd. P.O. Box 5398 Texarkana, Texas 75505-5398 [phone] [phone] -- Fax ATTORNEYS FOR PLAINTIFF ERIC ALBRITTON
JACKSON WALKER L.L.P.

By:/s/ Charles L. Babcock Charles L. Babcock Federal Bar No.: 10982 Email: cbabcockgjw.com Crystal J. Parker Federal Bar No.: 621142 Email: [e-mail] 1401 McKinney Suite 1900 Houston, Texas 77010 [phone] [phone] --Fax ATTORNEYS FOR DEFENDANT CISCO SYSTEMS, INC.

AGREED MOTION TO EXTEND THE DISCOVERY AND MOTION FOR SUMMARY JUDGMENT DEADLINES -Page 2-

GEORGE MCWILLIAMS,

P.C.

/s/ George L. McWilliams By: by permission Charles L. Babcock George L. McWilliams Texas Bar No: 13877000 GEORGE L. MCWILLIAMS, P.C. 406 Walnut P.O. Box 58 Texarkana, Texas 75504-0058 [phone] [phone]--Fax Email: glmlawoffice(&gmail.corn ATTORNEY FOR DEFENDANT RICHARD FRENKEL
CERTIFICATE OF SERVICE

This is to certify that on this 6 th day of July, 2009, a true and correct copy of the foregoing was served upon: George L. McWilliams 406 Walnut P.O. Box 58 Texarkana, Texas 75504-0058 Attorney for Defendant Richard Frenkel Patricia L. Peden Law Offices of Patricia L. Peden 5901 Christie Avenue Suite 201 Emeryville, CA 94608 Attorney for Plaintiff Eric Albritton James A. Holmes 605 South Main Street, Suite 203 Henderson, Texas 75654 Attorney for Plaintiff Eric Albritton

Nicholas H. Patton Patton, Tidwell & Schroeder, LLP 4605 Texas Boulevard P.O. Box 5398 Texarkana, Texas 75505-5398 Attorney for Plaintiff Eric Albritton

/s/ Charles L. Babcock Charles L. Babcock

AGREED MOTION TO EXTEND THE DISCOVERY AND MOTION FOR SUMMARY JUDGMENT DEADLINES -Page 35553185v.1