Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 1240

Unopposed MOTION for Leave to File SUPPLEMENTAL BRIEFING IN SUPPORT OF THEIR MOTION TO EXCLUDE THE EXPERT REPORTS AND OPINIONS OF ROY WEINSTEIN [#905] by Google Inc., YouTube, LLC. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION

EOLAS TECHNOLOGIES, INC.
PLAINTIFF,

v.
ADOBE SYSTEMS INC., et al.,
DEFENDANTS.

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Civil Action No. 6:09-CV-446-LED

JURY TRIAL DEMANDED

GOOGLE, INC. AND YOUTUBE, LLC’S UNOPPOSED MOTION FOR LEAVE TO
FILE SUPPLEMENTAL BRIEFING IN SUPPORT OF THEIR MOTION TO EXCLUDE
THE EXPERT REPORTS AND OPINIONS OF ROY WEINSTEIN [#905]
NOW COMES Defendants Google, Inc. and YouTube, LLC (“Google”) and files this
Unopposed Motion for Leave to File Supplemental Briefing In Support of their Motion to
Exclude the Expert Reports and Opinions of Roy Weinstein [#905] and would show the Court as
follows:
1. On August 19, 2011, Google filed their Motion to Exclude the Expert Reports and
Opinions of Roy Weinstein which is docketed as #905. The parties’ briefing to this
motion including response, reply and surreply were subsequently filed on October 5,
2011, October 17, 2011, and October 27, 2011, respectively.
2. The deposition of Roy Weinstein occurred on January 4, 5, and 6, 2012. Based on
information provided and discussed at Mr. Weinstein’s recent deposition, Google

{A07/7713/0013/W0609471.1 }

respectfully requests leave to supplement its briefing regarding its Motion to Exclude
the Expert Reports and Opinions of Roy Weinstein [#905].
3. Google respectfully requests that they be allowed to file their supplemental briefing
by midnight on Saturday, January 14, 2012. Google also requests that Plaintiff be
allowed to file a supplemental response by midnight on Saturday, January 21, 2012.
Both Google’s supplemental brief and Plaintiff’s response would be limited to 10
pages.
4. Plaintiff is unopposed to the relief sought in this motion.

Dated: January 14, 2012

Respectfully submitted,

By: /s/ Michael E. Jones
Douglas E. Lumish
[e-mail]
Jeffrey G. Homrig
[e-mail]
Jonathan K. Waldrop (pro hac vice)
[e-mail]
Joseph H. Lee (pro hac vice)
[e-mail]
Parker C. Ankrum (pro hac vice)
[e-mail]
KASOWITZ BENSON TORRES &
FRIEDMAN LLP
333 Twin Dophin Dr., Suite 200
Redwood Shores, CA 94065
Telephone: [phone]
Facsimile: [phone]

{A07/7713/0013/W0609471.1 }

James R. Batchelder (pro hac vice)
[e-mail]
Sasha G. Rao (pro hac vice)
[e-mail]
Mark D. Rowland
[e-mail]
Brandon Stroy (pro hac vice)
[e-mail]
Lauren Robinson (pro hac vice)
[e-mail]
Rebecca R. Hermes (pro hac vice)
[e-mail]
Han Xu (pro hac vice)
[e-mail]
ROPES & GRAY LLP
1900 University Avenue, 6th Floor
East Palo Alto, California 94303-2284
Telephone: [phone]
Facsimile: [phone]
Michael E. Jones (Bar No. 10929400)
[e-mail]
Allen F. Gardner (Bar No. 24043679)
[e-mail]
POTTER MINTON
A Professional Corporation
110 N. College, Suite 500
Tyler, TX 75702
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR DEFENDANTS
GOOGLE, INC. AND YOUTUBE, LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have
consented to electronic service are being served with a copy of this document via the Court’s
CM/ECF system per Local Rule CV-5(a)(3) on January 14, 2012.

/s/ Michael E. Jones

{A07/7713/0013/W0609471.1 }