Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 470

Unopposed MOTION for Extension of Time to Complete Discovery by Playboy Enterprises International, Inc.. (Attachments: # 1 Text of Proposed Order)(Fedock, John)

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Eolas Technologies Incorporated v. Adobe Systems Incorporated et al Doc. 470 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Eolas Technologies Incorporated, Plaintiff, v. Adobe Systems Inc., 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. Penny 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. C.A. NO. 6:09-CV-446 (LED) JURY TRIAL DEMANDED UNOPPOSED MOTION OF PLAYBOY ENTERPRISES INTERNATIONAL FOR EXTENSION OF TIME TO COMPLETE CERTAIN DISCOVERY Defendant Playboy Enterprises International, Inc. ("Playboy") respectfully moves the Court to extend its deadline for rolling document production from October 20, 2010 (Dkt. 443) until October 29, 2010. Playboy has produced documents to Plaintiff and will continue to produce documents to Plaintiff on a rolling basis. While gathering documents for production, Playboy has discovered additional materials related to print advertising. Playboy has found the format of these materials to require additional time to collect and process. Accordingly, Playboy has requested additional time to complete this portion of its document production. Playboy will continue to review and produce this material on a rolling basis as quickly as reasonably possible, and has reached an Dockets.Justia.com understanding with Eolas that additional time is required to complete Playboy's production. The parties have met and conferred, and agreed that Playboy should endeavor to complete its rolling document production by October 29, 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, Playboy respectfully moves the Court for an Order extending the deadline for Defendant Playboy Enterprises International, Inc., to complete its rolling document production pursuant to Paragraph 2(b) of the Joint Agreed Discovery Order (Dkt. 247) until October 29, 2010. Dated: October 19, 2010 Respectfully submitted, /s/ John A Fedock David B. Weaver (TX Bar No. 00798576) Avelyn M. Ross (TX Bar No. 24027871) Gentry C. McLean (TX Bar No. 24046403) John A. Fedock (TX Bar No. 24059737) VINSON & ELKINS L.L.P. 2801 Via Fortuna, Suite 100 Austin, Texas 78746-7568 Tel: (512) 542-8400 Fax: (512) 236-3218 dweaver@velaw.com aross@velaw.com gmclean@velaw.com jfedock@velaw.com Counsel for Playboy Enterprises International, Inc. 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 19, 2010. Any other counsel of record will be served by first class mail on this same date. /s/ John A. Fedock John A. Fedock

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