Aloft Media, LLC v. Yahoo! Inc. et al

Filing 66

Joint MOTION for Extension of Time to File a Proposed Protective Order by Aloft Media, LLC, Yahoo! Inc., Google, Inc.. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

Aloft Media, LLC v. Yahoo! Inc. et al

Doc. 66

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION Aloft Media, LLC v. Yahoo! Inc., Google, Inc., and AOL LLC § § § § §

Civil Action No. 6:08-cv-509 JURY TRIAL DEMANDED

JOINT MOTION FOR EXTENSION OF TIME TO FILE A PROPOSED PROTECTIVE ORDER TO THE HONORABLE UNITED STATES DISTRICT COURT JUDGE: COMES NOW, Plaintiff ALOFT MEDIA, LLC (hereinafter referred to as "Plaintiff") and Defendants YAHOO! INC. and GOOGLE INC., (hereinafter collectively referred to as "Defendants") to file this their Joint Motion for Extension of Time to File Proposed Protective Order, and for their Motion would respectfully show to the Court the following: The current deadline for the parties to file a proposed Order is June 10, 2009. The parties respectfully request a seven (7) day extension of time up to and including June 17, 2009, in which to file their proposed Protective Order. The additional time will increase the chances that the proposed Order will be agreed. WHEREFORE, ABOVE PREMISES CONSIDERED, the Plaintiff and Defendants respectfully request that their Motion be granted, and that the deadline to file a proposed Protective Order be extended from June 10, 2009, to and including June 17, 2009.

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Dockets.Justia.com

Dated: June 11, 2009

Respectfully submitted, By:/s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 Allen F. Gardner State Bar No. 24043679 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P.O. Box 359 Tyler, Texas 75710 [phone] [phone] (Facsimile) [e-mail] [e-mail] Robert Perry [e-mail] Scott Weingaertner [e-mail] Christopher Carnaval [e-mail] KING & SPALDING LLP 1185 Avenue of the Americas New York, NY 10036 F: 212-556-2222 ATTORNEYS FOR DEFENDANT GOOGLE INC. By:/s/ Michael Jacobs, with permission by Michael E. Jones Michael Jacobs [e-mail] Brooks Beard [e-mail] MORRISON & FOERSTER, LLP 425 Market Street San Francisco, CA 94105 Tel: [phone] Fax: [phone]

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Otis Carroll Deborah Race IRELAND, CARROLL & KELLEY, PC 6101S. Broadway, Suite 500 Tyler, Texas 75703 Tel: [phone] Fax: [phone] [e-mail] ATTORNEYS FOR DEFENDANT YAHOO! INC. /s/ Craig Tadlock (with permission by Michael E. Jones) Eric M. Albritton [e-mail] Adam A. Biggs [e-mail] Craig Tadlock [e-mail] ALBRITTON LAW FIRM PO Box 2649 Longview, TX 75606 111 West Tyler Street, Longview, TX 75601 Thomas John Ward, Jr. [e-mail] WARD & SMITH LAW FIRM P.O. Box 1231 Longview, TX 75606-1231 Tel: [phone] Fax: [phone] Danny L. Williams [e-mail] Chris Cravey [e-mail] Matthew R. Rodgers [e-mail] Michael Benefield [e-mail] WILLIAMS MORGAN & AMERSON, P.C. 10333 Richmond, Suite 1100 Houston, TX 77042 3
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Tel: [phone] Fax: [phone] Scott E. Stevens [e-mail] Kyle J. Nelson [e-mail] STEVENS LAW FIRM P.O. Box 807 Longview, TX 75606 Tel: [phone] Fax: [phone] ATTORNEYS FOR PLAINTIFF ALOFT MEDIA, LLC CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on June 11, 2009. Any other counsel of record will be served by U.S. first class mail on this same date. /s/ Michael E. Jones Michael E. Jones

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