Aloft Media, LLC v. Oracle Corporation et al

Filing 97

Unopposed MOTION for Extension of Time to File P.R. 3-1 and 3-2 Disclosures by Aloft Media, LLC. (Attachments: # 1 Text of Proposed Order)(Albritton, Eric)

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-LED JURY TRIAL DEMANDED

PLAINTIFF ALOFT MEDIA, LLC'S UNOPPOSED MOTION TO EXTEND THE DEADLINE FOR ITS P.R. 3-1 AND 3-2 DISCLOSURES Aloft Media, LLC ("Aloft Media"), plaintiff in the above-entitled and numbered civil action, moves to extend the deadline for Plaintiff to serve its P.R. 3-1 and 3-2 disclosures until the date set by the agreed docket control order, which will be filed by June 21, 2010. In support of this motion, Aloft Media would respectfully show the Court the following. Pursuant to the Court's May 18, 2010, Order setting a status conference on June 7, 2010 (Docket No. 96), Aloft Media's P.R. 3-1 and 3-2 disclosures are due June 11, 2010. The agreed docket control order is due June 21, 2010. Counsel for Aloft Media and each defendant have agreed to extend the P.R. 3-1 and 3-2 disclosure deadline until the date set by the agreed docket control order. WHEREFORE, PREMISES CONSIDERED, Aloft Media prays that the Court extend the deadline for Plaintiff to serve its P.R. 3-1 and 3-2 disclosures until the date set by the agreed docket control order, and for all other relief to which it is justly entitled.

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Respectfully submitted,

Eric M. Albritton Texas State Bar No. 00790215 [e-mail] Adam A. Biggs Texas State Bar No. 24051753 [e-mail] Debra Coleman Texas State Bar No. 24059595 [e-mail] Matthew C. Harris Texas State Bar No. 24059904 [e-mail] ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] T. John Ward, Jr. Texas State Bar No. 00794818 [e-mail] WARD & SMITH LAW FIRM P.O. Box 1231 Longview, TX 75606-1231 Telephone: [phone] Facsimile: [phone] Danny L. Williams Texas State Bar No. 21518050 [e-mail] J. Mike Amerson Texas State Bar No. 01150025 [e-mail] Christopher N. Cravey Texas State Bar No. 24034398 [e-mail] Matthew R. Rodgers Texas State Bar No. 24041802 [e-mail] Michael A. Benefield Indiana Bar No. 24560-49

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[e-mail] WILLIAMS, MORGAN & AMERSON, P.C. 10333 Richmond, Suite 1100 Houston, Texas 77042 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF Aloft Media, LLC CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email, on this the 19th day of May 2010.

____________________________________ Eric M. Albritton CERTIFICATE OF CONFERENCE Counsel for each defendant has advised that it is unopposed to the relief requested.

____________________________________ Eric M. Albritton

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