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

Filing 644

Unopposed MOTION to Extend Discovery Deadline for 3 Fact Witness Depositions by Google Inc.. (Attachments: #1 Text of Proposed Order)(Jones, Michael)

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

Doc. 644

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., CITIWARE TECHNOLOGY SOLUTIONS, LLC, GOOGLE INC., YAHOO! INC., MYSPACE INC., AMAZON.COM INC., PAYPAL INC., MATCH.COM, LLC., AOL LLC, and CME GROUP INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO. 6:09-CV-00269 Hon. Leonard E. Davis JURY TRIAL DEMANDED

GOOGLE INC.'S UNOPPOSED MOTION TO EXTEND DISCOVERY DEADLINE FOR THREE FACT WITNESS DEPOSITIONS Defendant Google Inc. ("Defendant") files this Motion to Extend Discovery Deadline for Three Fact Witness Depositions, and would respectfully show the Court the following. The deadline for the completion of discovery in the above-referenced cause was January 10, 2011 [DKT #341]. Defendant respectfully requests that the deadline be extended to March 30, 2011 for the sole purpose of conducting the depositions of the following fact witnesses: Laurent Chavey: March 29, 2011 (the Court ordered Defendant Google to produce Mr. Chavey for an additional three hours of deposition testimony by order of March 4, 2011 [DKT #548]) Lucas Pereira: March 29, 2011 Michael Waychison: March 30, 2011

Plaintiff Bedrock Computer Technologies, LLC does not oppose the relief sought by this motion. This extension of time is needed to accommodate the schedules of all parties. The

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granting of this motion will not change any other deadline set forth in the Court's Docket Control Orders. WHEREFORE, PREMISES CONSIDERED, Defendant respectfully requests that this Motion be granted, and that the deadline for the completion of discovery be extended to and including March 30, 2011 for the sole purpose of conducting the depositions of the three identified fact witnesses. All other case deadlines would remain unchanged.

March 23, 2011

Respectfully submitted, /s/ Evette D. Pennypacker, with permission by Michael E. Jones Claude M. Stern [e-mail] Todd M. Briggs [e-mail] QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., Suite 560 Redwood Shores, CA 94065 Telephone: [phone] Facsimile: 650-801-5100 Michael E. Jones State Bar No. 10929400 [e-mail] POTTER MINTON 110 N. College Tyler, Texas 75702 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Google Inc. and Match.com, LLC

CERTIFICATE OF SERVICE The undersigned hereby certifies that counsel of record who are deemed to have consented to electronic service are being served with a copy of the foregoing document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on March 23, 2011.

By: /s/ Michael E. Jones Michael E. Jones