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

Filing 287

Unopposed MOTION for Extension of Time to File Response/Reply as to #263 SEALED PATENT MOTION to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of Non-Privileged Documents on Bedrock's Privilege Log by AOL Inc, Google Inc., Match.Com LLC, MySpace Inc., Yahoo! Inc.. (Attachments: #1 Text of Proposed Order)(Jones, Michael)

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

Doc. 287

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

CASE NO. 6:09­CV­00269 Hon. Leonard E. Davis

JURY TRIAL DEMANDED

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANTS TO FILE THEIR REPLY IN SUPPORT OF THEIR MOTION TO COMPEL NON-PRIVILEGED TESTIMONY AND DOCUMENTS FROM MIKHAIL LOTVIN AND BEDROCK AND REQUEST FOR IN CAMERA REVIEW OF NON-PRIVILEGED DOCUMENTS ON BEDROCK'S PRIVILEGE LOG COMES NOW, Defendants Google Inc., Match.com, LLC, MySpace Inc., AOL Inc., and Yahoo! Inc. ("Defendants") and files this Unopposed Motion for Extension of Time for Defendants to File their Reply in Support of their Motion to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of NonPrivileged Documents on Bedrock's Privilege Log, and would respectfully show the Court as follows: 1. 2. On August 9, 2010, Defendants filed their Motion to Compel [Dkt. #263]. On September 3, 2010, Plaintiff filed its Response in Opposition to Defendants' Motion to Compel, [Dkt. #277].

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Dockets.Justia.com

3.

On September 9, 2010, Plaintiff filed an Unopposed Motion for Extension of

Time for a one week extension to submit proof supporting Bedrock's claim of privilege and work product through September 16, 2010. 4. Defendants' Reply is currently due on September 13, 2010. By this Motion,

Defendants seek an extension to and including September 20, 2010, in which to file their Reply to Plaintiff's Response to Defendants' Motion to Compel. Defendants seek this extension to allow them to address in their reply any proof submitted by Bedrock on September 16, 2010 to support its claim of privilege and work product. 5. Plaintiff does not oppose this extension.

WHEREFORE, PREMISES CONSIDERED, Defendants pray that the Court grant this Unopposed Motion for Extension of Time by extending the time period for Defendants to file their Reply in support of their Motion to Compel Non-Privileged Testimony and Documents from Mikhail Lotvin and Bedrock and Request for In Camera Review of Non-Privileged Documents on Bedrock's Privilege Log up to and including September 20, 2010. Dated: September 13, 2010 Respectfully submitted, By: /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 POTTER MINTON A PROFESSIONAL CORPORATION 110 N. College Ave., Ste. 500 Tyler, Texas 75702 Telephone: (903) 597­8311 Facsimile: (903) 593­0846 Email: [e-mail]

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Claude M. Stern Todd M. Briggs Evette D. Pennypacker QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Telephone: 650­801­5000 Facsimile: 650­801­5100 Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant Match.com LLC and Google, Inc. /s/ Yar Chaikovsky (with permission by Michael E. Jones) Yar R. Chaikovsky [e-mail] McDERMOTT WILL & EMERY 275 Middlefield Road, Suite 100 Menlo Park, CA 94025 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Yahoo! Inc. /s/ Alan Whitehurst (with permission by Michael E. Jones) Alan L. Whitehurst [e-mail] ALSTON & BIRD LLP The Atlantic Building 950 F Street, N.W. Washington, DC 20004 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants MySpace Inc. and AOL LLC. CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to 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 September 13, 2010. Any other counsel of record will be served by First Class U.S. mail on this same date. /s/ Michael E. Jones

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