Aloft Media, LLC v. Oracle Corporation et al

Filing 160

Unopposed MOTION to Produce Documents by Halliburton Co.. (Attachments: # 1 Text of Proposed Order)(Aurentz, Phillip)

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Aloft Media, LLC v. Oracle Corporation et al Doc. 160 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ALOFT MEDIA, LLC, Plaintiff, v. ORACLE CORPORATION, ET AL., Defendants. Civil Action No. 6:09-CV-304 JURY TRIAL DEMANDED DEFENDANT HALLIBURTON'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO PRODUCE DOCUMENTS Defendants Halliburton Company and Halliburton Energy Services, Inc. ("Halliburton"), file this Unopposed Motion for Extension of Time to Produce Documents. Halliburton requests, with the consent of Plaintiff Aloft Media, LLC, that the Court amend its June 21, 2010 Discovery Order [Dkt. No. 107] to allow Halliburton to complete its rolling production of documents by January 28, 2011. The parties have agreed to a 60 day extension of time for Halliburton to produce responsive documents. This extension of time is intended to enable Halliburton to comply with its document production obligations and is not sought for delay. At this time the parties do not contemplate that other deadlines in this case will be affected. A proposed Order granting this motion is attached hereto. PAGE 1 Dallas 312724v1 Date: November 18, 2010 Respectfully submitted, McKool Smith, P.C. By: /s/ Phillip Aurentz Theodore Stevenson, III Texas State Bar No. 19196650 Aimee Perilloux Fagan Texas State Bar No. 24010299 Phillip Aurentz Texas State Bar No. 24059404 McKool Smith, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone: (214) 978-4000 Telecopier: (214) 978-4044 Attorneys for Defendants Halliburton Company and Halliburton Energy Services, Inc. PAGE 2 Dallas 312724v1 CERTIFICATE OF CONFERENCE On November 11, 2010, the undersigned spoke with Eric M. Albritton, attorney for Plaintiff Aloft Media, LLC. Mr. Albritton stated that Plaintiff did not oppose the relief sought in this motion. /s/ Phillip Aurentz CERTIFICATE OF SERVICE The undersigned certifies that, on November 18, 2010, the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). /s/ Phillip Aurentz PAGE 3 Dallas 312724v1

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