EMG Technology, LLC v. Apple, Inc.

Filing 136

Unopposed MOTION for Extension of Time to File by United Parcel Service, Inc.. (Attachments: # 1 Text of Proposed Order)(Abhyankar, Siraj)

EMG Technology, LLC v. Apple, Inc.

Doc. 136

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EMG TECHNOLOGY, LLC, Plaintiff, v. APPLE, INC., AMERICAN AIRLINES, INC., BLOOMBERG, L.P., CONTINENTAL AIRLINES, INC., UNITED PARCEL SERVICE, INC., DELL, INC. Defendants. DEFENDANT UNITED PARCEL SERVICE, INC.'S UNOPPOSED MOTION FOR EXTENSION OF CERTAIN DEADLINES Defendant United Parcel Service, Inc. ("UPS") hereby files this Unopposed Motion for Extension of Certain Deadlines in the above referenced case 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. UPS requests an extension until October 21, 2009. The current deadline for UPS to answer the Fourth Amended Complaint is September 21, 2009. UPS requests an extension until October 21, 2009. Plaintiff does not oppose the requests in this motion. Dated this 21st day of September, 2009. JURY TRIAL DEMANDED CIVIL ACTION NO. 6:08-cv-447 (LED)

/s/ Siraj M. Abhyankar Jason W. Cook Texas Bar No. 24028537

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[e-mail] ALSTON & BIRD LLP Chase Tower 2200 Ross Avenue, Suite 3601 Dallas, TX 75201 Tel: [phone] Fax: [phone] Patrick J. Flinn Lead Attorney Georgia Bar No. 264540 [e-mail] Robert L. Lee Georgia Bar No. 443978 [e-mail] Siraj M. Abhyankar Georgia Bar No. 484680 [e-mail] Jennifer R. Liotta Georgia Bar No. 109528 [e-mail] ALSTON & BIRD LLP 1201 West Peachtree Street Atlanta, GA 30309-3424 Tel: [phone] Fax: [phone] Counsel for Defendant and Counterclaim Plaintiff UNITED PARCEL SERVICE, INC.

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EMG TECHNOLOGY, LLC, Plaintiff, v. APPLE, INC., AMERICAN AIRLINES, INC., BLOOMBERG, L.P., CONTINENTAL AIRLINES, INC., UNITED PARCEL SERVICE, INC., DELL, INC. Defendants. 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. /s/ Siraj M. Abhyankar_ Siraj M. Abhyankar JURY TRIAL DEMANDED CIVIL ACTION NO. 6:08-cv-447 (LED)

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 21st day of September 2009, with a copy of this document via this Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Siraj M. Abhyankar____ Siraj M. Abhyankar