Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1237

Agreed MOTION for Extension of Time to File by Citigroup Inc., Eolas Technologies Incorporated. (Attachments: # 1 Text of Proposed Order)(Fuller, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
EOLAS TECHNOLOGIES, INC., AND
THE REGENTS OF THE UNIVERSITY
OF CALIFORNIA
Plaintiffs,
v.
ADOBE SYSTEMS, INC., et al.,
Defendants.

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No. 6:09-cv-00446-LED

AGREED MOTION TO EXTEND DEADLINES

Defendant Citigroup Inc. and Plaintiffs Eolas Technologies, Inc. and The Regents of the
University of California (collectively as “the Parties”) hereby jointly and respectfully request that
the deadlines associated with the briefing of Defendant Citigroup’s Daubert Motion directed to
Plaintiff’s expert Roy Weinstein be extended by two weeks in order to allow the Parties an
opportunity to finalize a settlement agreement and stipulation of dismissal. The parties have
reached an oral agreement to settle this case, subject to the drafting and execution of a written
agreement that is acceptable to both parties. The Parties intend to execute and file the necessary
documents and stipulation of dismissal on or before January 27, 2012.
The Parties therefore respectfully request that the deadline for Citigroup to file its Reply
in Support of its Daubert Motion be extended to January 27, 2012, and the corresponding
deadline for Plaintiffs to file their Sur-Reply be extended to February 3, 2012.

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Respectfully submitted:
/s/ M. Scott Fuller
Edwin R. DeYoung
Texas Bar No. 05673000
Roy W. Hardin
Texas Bar No. 08968300
Roger Brian Cowie
Texas Bar No. 00783886
M. Scott Fuller
Texas Bar No. 24036607
Galyn Gafford
Texas Bar No. 24040938
LOCKE LORD LLP
2200 Ross Avenue, Suite 2200
Dallas, Texas 75201-6776
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
ATTORNEYS FOR DEFENDANT
CITIGROUP INC.

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/s/ Mike McKool
Mike McKool
Lead Attorney
Texas Bar No. 13732100
[e-mail]
Douglas Cawley
Texas Bar No. 04035500
Holly Englemann
Texas Bar No. 24040865
McKool Smith, P.C.
300 Crescent Court, Suite 1500
Dallas, Texas 75201
Telephone: [phone]
Telecopier: [phone]
Kevin L. Burgess
Texas Bar No. 24006927
John B. Campbell
Texas Bar No. 24036314
Josh W. Budwin
Texas Bar No. 24050347
Gretchen K. Curran
Texas Bar No. 24055979
Matthew B. Rappaport
Texas Bar No. 24070472
McKool Smith, P.C.
300 West Sixth Street, Suite 1700
Austin, Texas 78701
Telephone: [phone]
Telecopier: [phone]
ATTORNEYS FOR PLAINTIFFS
EOLAS TECHNOLOGIES, INC., AND
THE REGENTS OF THE UNIVERSITY
OF CALIFORNIA

CERTIFICATE OF SERVICE
The undersigned certifies that on the 13th day of January, 2012, the foregoing document
was filed electronically in compliance with Local Rule CV-5(a). As such, this document was
served on all counsel who have consented to electronic service.
/s/ M. Scott Fuller

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