Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 332

Unopposed MOTION for Extension of Time to Complete Discovery Pursuant to Paragraph 2(B) of the Joint Agreed Discovery Order by Apple Inc.. (Attachments: # 1 Text of Proposed Order)(Donahey, Teague)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EOLAS TECHNOLOGIES, INC., Plaintiff, vs. ADOBE SYSTEMS, INC., ET AL., Defendants. AND RELATED COUNTERCLAIMS Civil Action No. 6:09-cv-446-LED

DEFENDANT APPLE INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE ROLLING DOCUMENT PRODUCTION PURSUANT TO ¶ 2(B) OF THE JOINT AGREED DISCOVERY ORDER Defendant Apple Inc. ("Apple") respectfully moves the Court to extend the deadline for Apple to complete its rolling document production pursuant to Paragraph 2(B) of the Joint Agreed Discovery Order [Docket No. 247] from August 4, 2010 until September 29, 2010, and would show the Court as follows: I. Pursuant to the Joint Agreed Discovery Order entered by this Court on April 2, 2010 [Docket No. 247], the deadline for the parties to complete their Paragraph 2(B) rolling document productions is August 4, 2010. Apple has been working diligently to meet this date but, despite its efforts, seeks additional time to complete its production. The parties have met and conferred and this Motion is unopposed. Plaintiff Eolas Technologies, Inc. ("Eolas") has agreed that Apple may extend the August 4, 2010 deadline by eight weeks, or until September 29, 2010.

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This additional eight week extension will ensure that Apple has sufficient time to complete its obligations under ¶ 2(B) of the Joint Agreed Discovery Order. II. This motion is not made for delay, and should not impact any other deadline applicable to this litigation. III. Accordingly, Apple respectfully requests that the Court grant this unopposed Motion and extend the deadline for Apple to complete its Paragraph 2(B) rolling document production pursuant to the Joint Agreed Discovery Order [Docket No. 247] from August 4, 2010 until September 29, 2010.

Dated: June 23, 2010 /s/Teague I. Donahey David T. Pritikin [e-mail] Richard A. Cederoth [e-mail] SIDLEY AUSTIN LLP One South Dearborn Chicago, Illinois 60603 Telephone: [phone] Facsimile: [phone] Theodore W. Chandler [e-mail] SIDLEY AUSTIN LLP 555 W. Fifth Street Los Angeles, California 90013 Telephone: [phone] Facsimile: [phone]

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Teague I. Donahey [e-mail] SIDLEY AUSTIN LLP 555 California Street San Francisco, California 94104 Telephone: [phone] Facsimile: [phone] Eric M. Albritton Texas State Bar No. 00790215 [e-mail] ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant APPLE INC.

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), 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 23rd day of June, 2010. /s/Duy D. Nguyen CERTIFICATE OF CONFERENCE I hereby certify that on June 18, 2010, Josh Budwin, counsel for Eolas Technologies Inc., informed me that Eolas has no opposition to this Motion for Extension. /s/Teague I. Donahey

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