Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 431

Unopposed MOTION for Extension of Time to Complete Discovery (Certain) by CDW Corporation. (Attachments: # 1 Text of Proposed Order)(Gabrielson, Anthony)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 431

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION Eolas Technologies Incorporated, Plaintiff, vs. Adobe Systems Inc., Amazon.com, Inc., Apple Inc., Blockbuster Inc., CDW Corp., Citigroup Inc., eBay Inc., Frito-Lay, Inc., The Go Daddy Group, Inc., Google Inc., J.C. Penney Company, Inc., JPMorgan Chase & Co., New Frontier Media, Inc., Office Depot, Inc., Perot Systems Corp., Playboy Enterprises International, Inc., Rent-A-Center, Inc., Staples, Inc., Sun Microsystems Inc., Texas Instruments Inc., Yahoo! Inc. and YouTube, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 6:09-cv-446 Judge Leonard E. Davis

JURY TRIAL DEMANDED

UNOPPOSED MOTION OF CDW LLC FOR EXTENSION OF TIME TO COMPLETE CERTAIN DISCOVERY Defendant CDW LLC ("CDW"), by its attorneys, Marshall, Gerstein & Borun LLP and Findlay Craft LLP, respectfully moves the Court to extend (i) its deadline for rolling document production from September 29, 2010 (Dkt. 381) until October 15, 2010, and (ii) its deadline for the exchange of privilege logs from October 16, 2010 (Dkt. 381) until November 3, 2010. CDW is producing documents to Plaintiff on a rolling basis and will continue to produce documents to Plaintiff on a rolling basis. CDW has identified certain additional documents and discussed the production of those documents with Plaintiff. In the

interim, CDW will continue to produce responsive documents to Eolas on a rolling basis.

Dockets.Justia.com

The parties have met and conferred, and agreed that CDW should endeavor to complete its rolling document production by October 15 and exchange privilege logs by November 3, 2010. As such, this motion is unopposed. This motion is not made for delay, and should not impact any other deadlines applicable to this litigation. Accordingly, CDW respectfully moves the Court for an Order extending the deadline for Defendant CDW to complete its rolling document production pursuant to Paragraph 2(b) of the Joint Agreed Discovery Order (Dkt. 247) until October 15 and to exchange their privilege logs pursuant to the Docket Control Order (Dkt. 249) until November 3, 2010. Dated: September 29, 2010 Respectfully submitted,

Thomas L. Duston [e-mail] Anthony S. Gabrielson [e-mail] Marshall, Gerstein & Borun LLP 6300 Sears Tower 233 South Wacker Drive Chicago, IL 60606-6357 [phone] Brian Craft [e-mail] Eric H. Findlay [e-mail] Findlay Craft, LLP 6760 Old Jacksonville Highway, Suite 101 Tyler, TX 75703 903-534-1100 Attorneys for Defendant CDW LLC

2

CERTIFICATE OF SERVICE I, Anthony S. Gabrielson, an attorney, hereby certify that on September 29, 2010, I caused a copy of the foregoing UNOPPOSED MOTION OF CDW LLC FOR EXTENSION OF TIME TO COMPLETE CERTAIN DISCOVERY to be electronically filed using the CM/ECF system, which sent notification of such filing to all counsel of record.

Anthony S. Gabrielson