Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 432

Unopposed MOTION for Extension of Time to Complete Discovery by Frito-Lay, Inc., Rent-A-Center, Inc.. (Attachments: # 1 Text of Proposed Order Granting Defendant Frito-Lay, Inc.'s and Rent-A-Center, Inc.'s Unopposed Motion for Extension of Time to Complete Certain Discovery)(Yee, Jeffrey)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 432

IN THE UMTED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION
Eolas Technologies Incorporated,
$ $ $ $ $ $ $

Plaintiff
v. Adobe Systems lnc., Amazon.com, Inc. Apple Inc., Argosy Publishing, 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, lnc., Staples, Inc., Sun Microsystems Inc., Texas Instruments Inc., Yahoo! Inc., and YouTube, LLC,
Defendants.

$ Civil Action No. 6:09-cv-00446-LED
$ $ $

$
$ $ $ $ $
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UNOPPOSED MOTION FOR EXTENSION OF TIME FOR FRITO-LAY,INC. AND RENT-A-CENTER.INC. TO COMPLETE CERTAIN DISCOVERY
Defendants Frito-Lay, Inc. and Rent-A-Center, Inc. (collectively "Defendants")

hereby move the Court for an extension of time to complete certain discovery. The parties have met and conferred regarding the relief requested herein and this motion is
unopposed.

The deadlines for the parties to conclude document production and exchange

privilege logs are currently set for September 29, 2010 and October 16, 2010,
respectively (Dkt No.

381). The parties have met and conferred and agreed that the

deadlines for completion of Defendants' document productions and service of a privilege logs, if any, should be extended to October 13,2010 and November

l,

2010,respectively.

Defendants have been diligently searching for responsive documents. In this regard,
UN0PP0SED MoTIoN FoR EXTENSIaN oF TIME To

CouprcTc CERTAIN DISC0VERY

PAGE

I

Dockets.Justia.com

Defendants are using, inter alia, search logic recently negotiated with Plaintiff to comb

through material collected from custodians and to identify documents for production.
Defendants are producing this material on a rolling basis as quickly as reasonably possible,

will continue to do so, and have

reached an understanding with Plaintiff that

additional time is required to complete Defendants' productions.

This motion is not made for delay, and should not impact any other deadlines
applicable to this litigation.

Accordingly, Frito-Lay, Inc, and Rent-A-Center, Inc. respectfully move the Court

for an order extending the deadlines for Frito-Lay, Inc. and Rent-A-Center, Inc. to
complete their rolling document productions pursuant

to

Paragraph 2(b)

of the

Joint

Agreed Discovery Order (Dkt No. 247) until October 13,2010, and to exchange their

privilege logs,

if

any, pursuant to the Docket Control Order (Dkt No. 249) until

November 1,2010.

Dated: September 29,2010
Respectful ly submitted,

/s/ Je.ffrey F. Yee GREENBERG TRAURIG LLP Jeffrey K. Joyner (admitted pro hac více) [e-mail] Jeffrey F. Yee (admittedpro hac vice) yeej@ølaw.com 2450 Colorado Avenue, Suite 4008 Santa Monica, California 90404 Telephone: (3 I 0) 586-7700 Facsimile: (3 I 0) 586-7800

BI.JETIIER JOE & CARPENTER, LLC Christopher M. Joe chris j oe@bj c ip law. com Brian Carpenter brian. camenterb@bj ciplaw. com
MoTIoN FoR EYTENSIoN oF TIME To CùMPLETE CERTAIN DIscoVERY

UN0PPOSED

PAGE 2

Erie W. Buether
eric.buethere@bj ciplaw. com 1700 Pacific, Suite 2390 Dallas, Texas 75201 Telephone : (2t4) 466-ln 0 Facsimile: (21 4) 63 5 -l 842

ATTORNEYS T()R DEFENDA¡TTS FRITO-LAY, INC. and RENT-A-

CENTER,INC.

UNOPPOSED MOTTON FOR EXTENSION OF TIME TO COMPLETE CERTAIN

DISCOVERY

PIEE 3

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 CMÆCF system per Local Rule CV-5(aX3) on September 29,2A10. Any
other counsel of record

will

be served by first class mail on this same date.

/s/ Jeffrev F Yee Jeffrey F. Yee

UUOPPOSøO MOTION FOR EXTENSION OF TIME TO COMPLETE CEßTATN

DTSCOVERY

PEEø 4