Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 282

Unopposed MOTION for Extension of Time to File by Bedrock Computer Technologies, LLC. (Attachments: #1 Text of Proposed Order)(Cawley, Douglas)

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Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al Doc. 282 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., et al. Defendants. CASE NO. 6:09-cv-269 Jury Trial Demanded BEDROCK'S UNOPPOSED MOTION FOR EXTENSION OF TIME Plaintiff Bedrock Computer Technologies LLC ("Bedrock") respectfully requests that the Court grant Bedrock an extension of time to file its "proof in the form of declarations or affidavits to support their assertions of privilege, along with the documents over which privilege is asserted for in camera inspection," pursuant to Paragraph 6 of the Discovery Order (Dkt. 173), dated February 3, 2010, in connection with Defendants' Motion to Compel Testimony and Documents from Mikhail Lotvin and Bedrock, and Request for In Camera Review of Documents on Bedrock's Privilege Log ("Motion to Compel") (Dkt. No. 263). Defendants filed their Motion to Compel on August 9, 2010. Bedrock's deadline to file its proof, as required by Paragraph 6 of the Discovery Order, is currently due on September 9, 2010. To accommodate attorney schedules and not for the purpose of delay, Bedrock respectfully requests a one-week extension, which would move the September 9th deadline to September 16, 2010, for Bedrock to submit proof supporting Bedrock's claims of privilege and work product. The defendants do not oppose this request. DATED: September 9, 2010 Respectfully submitted, McKOOL SMITH, P.C. /s/ Douglas A. Cawley Sam F. Baxter Texas Bar No. 01938000 McKOOL SMITH, P.C. 104 E. Houston Street, Suite 300 P.O. Box 0 Marshall, Texas 75670 Telephone: (903) 923-9000 Facsimile: (903) 923-9099 Douglas A. Cawley, Lead Attorney Texas Bar No. 04035500 Theodore Stevenson, III Texas Bar No. 19196650 J. Austin Curry Texas Bar No. 24059636 Jonathan R. Yim Texas Bar No. 24066317 McKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone: 214-978-4000 Facsimile: 214-978-4044 Robert M. Parker Texas Bar No. 15498000 Robert Christopher Bunt Texas Bar No. 00787165 PARKER, BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, Texas 75702 Telephone: 903-531-3535 Facsimile: 903-533-9687 E-mail: E-mail: ATTORNEYS FOR PLAINTIFF BEDROCK COMPUTER TECHNOLOGIES LLC 2 Dallas 308684v1 CERTIFICATE OF SERVICE The undersigned certifies that on September 9, 2010, true and correct copies of the foregoing document were filed via CM/ECF, and were thereby made available to all counsel of record. /s/ J. Austin Curry J. Austin Curry CERTIFICATE OF CONFERENCE Counsel for Plaintiff has conferred with Counsel for Defendants, and Defendants do not oppose the relief requested in this Motion. /s/ J. Austin Curry J. Austin Curry 3 Dallas 308684v1

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