Aloft Media, LLC v. Google, Inc.

Filing 24

Unopposed MOTION to Amend/Correct Extend Time to Comply With Local P.R. 3-1 and 3-2 by Aloft Media, LLC. (Attachments: #1 Text of Proposed Order)(Tadlock, Charles)

Aloft Media, LLC v. Google, Inc.

Doc. 24

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ALOFT MEDIA, LLC, Plaintiff, v. GOOGLE, INC. Defendant. § § § § § § § § § § §

Civil Action No. 6:08-CV-440 JURY TRIAL DEMANDED

PLAINTIFF'S UNOPPOSED MOTION TO EXTEND TIME TO COMPLY WITH LOCAL P.R. 3-1 AND 3-2 Plaintiff Aloft Media, LLC ("Plaintiff") files this Unopposed Motion to Extend Time for Plaintiff to serve its disclosures under Local P.R. 3-1 and 3-2, and would show unto the Court the following: Plaintiff has conferred with Defendant, which has agreed that the deadline for Plaintiff to serve its disclosures under Local P.R. 3-1 and 3-2 shall be extended from the current deadline of March 6, 2009. A date certain for such disclosures will be negotiated and presented to the Court for approval as part of the Docket Control Order, which is presently due to be submitted to the Court on or before March 16. 2009. WHEREFORE, PREMISES CONSIDERED, the Plaintiff, Aloft Media, LLC, respectfully requests the Court to grant the extension as set forth herein above.

Dockets.Justia.com

Respectfully submitted,

Eric M. Albritton Texas State Bar No. 00790215 Craig Tadlock Texas State Bar No. 00791766 Adam A. Biggs Texas State Bar No. 24051753 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 [phone] (phone) [phone] (fax) [e-mail] [e-mail] [e-mail] T. John Ward, Jr. Texas Bar No. 00794818 WARD & SMITH LAW FIRM P.O. Box 1231 Longview, TX 75606-1231 Telephone: [phone] Facsimile: [phone] [e-mail] Danny L. Williams Texas State Bar No. 21518050 Chris Cravey Texas State Bar No. 24034398 WILLIAMS, MORGAN & AMERSON, P.C. 10333 Richmond, Suite 1100 Houston, Texas 77042 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail]

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Scott E. Stevens State Bar No. 00792024 Kyle J. Nelson State Bar No. 24056031 STEVENS LAW FIRM P.O. Box 807 Longview, Texas 75606 Tel: [phone] Fax: [phone] [e-mail] [e-mail] Jason A. Holt Texas State Bar No. 24041122 Matthew M. Hill Texas State Bar No. 24041101 HILL & HOLT, P.L.L.C. P.O. Box 6945 Longview, TX 75608 [phone] (phone) [phone] (fax) [e-mail] [e-mail] ATTORNEYS FOR PLAINTIFF ALOFT MEDIA, LLC CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel, who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email, on this the 4th day of March, 2009.

_____________________________ Craig Tadlock

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