Albritton v. Cisco Systems, Inc. et al

Filing 51

MOTION for Extension of Time to Complete Discovery Plaintiff's Agreed Motion for Extension of the Discovery Deadline by Eric Albritton. (Attachments: # 1 Text of Proposed Order)(Holmes, James)

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Albritton v. Cisco Systems, Inc. et al Doc. 51 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 PLAINTIFF'S AGREED MOTION FOR EXTENSION OF THE DISCOVERY DEADLINE TO THE HONORABLE UNITED STATES DISTRICT JUDGE: COMES NOW, ERIC M. ALBRITTON, Plaintiff in the above-captioned cause and files this, his Agreed Motion for Extension of the Discovery Deadline and, in support thereof, would respectfully show unto the Court as follows: I. The Court's current Scheduling Order requires that discovery in this case be completed by November 7, 2008. Subject to the Court's approval, the parties have agreed to extend discovery until November 20, 2008. This additional time is necessary to enable the parties to timely complete the depositions of various fact witnesses in Texas, Illinois and California. The trial date will not be affected. WHEREFORE, PREMISES CONSIDERED, ERIC M. ALBRITTON respectfully prays that this Agreed Motion for Extension of the Discovery Deadline be, in all respects, GRANTED. Respectfully submitted, By: _______/s/_____________________ James A. Holmes (attorney in charge) State Bar No. 00784290 THE LAW OFFICE OF JAMES A. HOLMES, P.C. 605 SOUTH MAIN STREET, SUITE 203 HENDERSON, TX 75654 (903) 657-2800 (903) 657-2855 (fax) CERTIFICATE OF CONFERENCE I hereby certify to the Court that Defendants are not opposed to the relief sought herein. _______________/s/______________ James A. Holmes CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the foregoing Motion on all Counsel of Record via the electronic filing system for the Eastern District of Texas on this, the 3rd day of October 2008. _______________/s/______________ James A. Holmes

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