EMG Technology, LLC v. Apple, Inc.

Filing 133

Unopposed MOTION for Extension of Time to File by Bloomberg, L.P.. (Attachments: # 1 Text of Proposed Order)(Rambin, Daymon)

EMG Technology, LLC v. Apple, Inc.

Doc. 133

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

EMG TECHNOLOGY, LLC, Plaintiff,
v.

CASE NO.

6:08-cv-447

JURY TRIAL DEMANDED

APPLE, INC., AMERICAN AIRLINES, INC., BLOOMBERG, L.P., CONTINENTAL AIRLINES, INC., UNITED PARCEL SERVICE, INC., Defendants. UNOPPOSED MOTION FOR EXTENSION OF CERTAIN DEADLINES

COMES NOW Defendant, Bloomberg, L.P. and files this Unopposed Motion for Extension of Certain Deadlines in said cause and in support of such motion would respectfully request an extension of the following deadlines. Pursuant to the Court's July 20, 2009 Discovery Order, the

deadline for initial disclosures was September 3, 2009, Bloomberg, L.P. requests an extension until October 2, 2009. The current deadline for Bloomberg, L.P. to answer the Fourth Amended

Complaint is September 21, 2009, Bloomberg, L.P. requests an extension until October 2, 2009. Plaintiff is not opposed to the requests in this motion.

12619078.1

Dockets.Justia.com

DATED: September 18, 2009

Respectfully submitted,

By: lsi D. Jeffrey Rambin S. Calvin Capshaw, III State Bar No. 03783900 Elizabeth L. DeRieux State Bar No. 05770585 D. Jeffrey Rambin State Bar No. 00791478 Capshaw DeRieux, LLP 1127 Judson Road, Suite 220 Longview, Texas 75601 [phone] Telephone [phone] Facsimile E-mail: [e-mail] E-mail: [e-mail] E-mail: [e-mail] Of Counsel: John M. DiMatteo j [e-mail] Kelsey I. Nix [e-mail] WILLKIE F ARR & GALLAGHER LLP 787 Seventh Avenue New York, NY 10019 [phone] Phone [phone] Fax ATTORNEYS FOR DEFENDANT BLOOMBERG, L.P.

-212619078.1

CERTIFICATE OF CONFERENCE I certify that I have complied with the meet and confer requirement in Local Rule CV-7(H) and this motion is unopposed.

lsi D. Jeffrey Rambin

CERTIFICATE OF SERVICE I hereby certify that the following counsel of record who are deemed to have consented to electronic service are being served this 18th day of September, 2009, with a copy of this document via the Court's CMlECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served

by electronic mail, facsimile transmission andlor first class mail on this same date.

lsi D. Jeffrey Rambin
D. Jeffrey Rambin

-312619078.1