Aloft Media, LLC v. Google, Inc.

Filing 57

Opposed MOTION for Extension of Time to File to Suspend Deadlines by Aloft Media, LLC. (Attachments: #1 Text of Proposed Order)(Albritton, Eric)

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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 ALOFT MEDIA, LLC'S OPPOSED MOTION TO SUSPEND DEADLINES Aloft Media, LLC ("Aloft"), plaintiff in the above-entitled and numbered civil action, respectfully requests that the Court enter an Order suspending all deadlines in this case for a period of two weeks. Google Inc. refuses to agree to this motion; instead, it only will agree to address deadlines on a case by case basis. The parties reached an oral agreement to settle this case and have been negotiating the final written settlement agreement. This two weeks is necessary because Aloft just received a revised settlement agreement from Google Inc. today, and, the additional time is necessary to attempt to finalize the settlement agreement, and, if they cannot, to to undertake the necessary work to comply with the requirements of the Docket Control and Discovery Orders. WHEREFORE, PREMISES CONSIDERED, Aloft respectfully moves that the Court grant this Opposed Motion to Suspend Deadlines as set forth in the attached proposed order. Respectfully submitted, Eric M. Albritton Texas State Bar No. 00790215 Adam A. Biggs Texas State Bar No. 24051753 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 (903) 757-8449 (phone) (903) 758-7397 (fax) ema@emafirm.com aab@emafirm.com T. John Ward, Jr. Texas Bar No. 00794818 WARD & SMITH LAW FIRM P.O. Box 1231 Longview, TX 75606-1231 Telephone: (903) 757-6400 Facsimile: (903) 757-2323 jw@jwfirm.com Danny L. Williams Texas State Bar No. 21518050 Matthew R. Rodgers Texas Bar No. 24041804 Chris Cravey Texas State Bar No. 24034398 WILLIAMS, MORGAN & AMERSON, P.C. 10333 Richmond, Suite 1100 Houston, Texas 77042 Telephone: (713)934-4060 Facsimile: (713) 934-7011 danny@wmalaw.com cravey@wmalaw.com mrodgers@wmalaw.com ATTORNEYS FOR PLAINTIFF ALOFT MEDIA, LLC 2 CERTIFICATE OF CONFERENCE Counsel for defendants were consulted regarding this motion and advised that they are opposed to the relief sought by this motion. ______________________________ Eric M. Albritton 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 20th day of August, 2009. ___________________________ Eric M. Albritton 3

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