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)

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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. § § § § § § § § § § § 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. 1 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: (214) 740-8000 Facsimile: (214) 740-8800 E-mail: edeyoung@lockelord.com ATTORNEYS FOR DEFENDANT CITIGROUP INC. 2 /s/ Mike McKool Mike McKool Lead Attorney Texas Bar No. 13732100 mmckool@mckoolsmith.com 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: (214) 978-4000 Telecopier: (214) 978-4044 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: (512) 692-8700 Telecopier: (512) 692-8744 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 3

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