Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 444

Consent MOTION for Extension of Time to Complete Certain Discovery by Google Inc.. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 444

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EOLAS TECHNOLOGIES INCORPORATED, Plaintiff, v. ADOBE SYSTEMS INC., ET AL, Defendants. Hon. Leonard E. Davis JURY CASE NO. 6:09-cv-446

UNOPPOSED MOTION OF GOOGLE INC. FOR EXTENSION OF TIME TO COMPLETE CERTAIN DISCOVERY Defendant Google Inc. respectfully moves the Court for an extension of time as it applies to the production of materials and information relating only to Google Instant for (i) the deadline for rolling document production from October 29, 2010 (Dkt. 421) until November 29, 2010, (ii) the deadline for source code production until November 29, 2010, and (iii) the deadline for the exchange of privilege logs from November 16, 2010 (Dkt. 421) until December 16, 2010. Pursuant to the Court granting Plaintiff's Unopposed Motion for Leave to Supplement its P.R. 3-1 Infringement Contentions with Respect to Google's Newly Added Google Instant Functionality [Dkt #436], Google Inc. requests this additional time for its rolling production, source code production, and privilege log exchange with regard to Google Instant functionality. Plaintiff is unopposed to this extension request.

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Dockets.Justia.com

This motion is not made for delay, and should not impact any other deadlines applicable to this litigation. Accordingly, Defendant Google Inc. respectfully moves the Court for an Order extending its deadline as relating to Google Instant only to complete its rolling document production and source code production pursuant to Paragraph 2(b) of the Joint Agreed Discovery Order (Dkt. 247) until November 29, 2010 and to exchange its privilege log pursuant to the Docket Control Order (Dkt. 249) until December 16, 2010. Dated: October 4, 2010 Respectfully submitted, By: /s/ Michael E. Jones _________________ Michael E. Jones State Bar No. 10929400 Allen F. Gardner State Bar No. 24043679 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P.O. Box 359 Tyler, Texas 75710 [phone] [phone] (Facsimile) [e-mail] [e-mail]

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Scott T. Weingaertner [e-mail] Robert F. Perry [e-mail] Christopher C. Carnaval [e-mail] Mark H. Francis [e-mail] KING & SPALDING LLP 1185 Avenue of the Americas New York, NY 10036-4003 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 October 4, 2010. Any other counsel of record will be served by First Class U.S. mail on this same date.

/s/ Michael E. Jones

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