Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 480

Unopposed MOTION for Extension of Time to Complete Discovery by J.C. Penney Company, Inc.. (Attachments: # 1 Text of Proposed Order Granting Defendant J.C. Penney Corporation, Inc.'s Unopposed Motion for Extension of Time to Complete Certain Discovery)(Yee, Jeffrey)

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Eolas Technologies Incorporated v. Adobe Systems Incorporated et al Doc. 480 IN TIIE UMTED 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 Cotp., Citigroup Inc., eBay Inc., Frito-Lay,Inc., The Go Daddy Group,lnc., Google lnc., J.C. Penney Company, Inc., JPMorgan Chase & Co.,New Frontier Media, Inc., Office Depot,Inc., Perot Systems Cotp., Playboy Enterprises Intemational, 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-00446-LED $ $ $ $ $ $ $ $ $ $ $ UNOPPOSED MOTION FOR EXTENSION OF TIME FOR J.C. PENNEY CORPORATION.INC.. PROVIDED IT IS ADDED AS A PARTY. TO COMPLETE CERTAIN DISCOVERY J.C. Penney Corporation, Inc.l ("J.C. Penney Corporation"), provided Eolas Technologies Incorporated ("Eolas") properly names it in the Complaint, hereby moves the Court for an extension of time to complete certain discovery. The parties have conferred regarding the relief requested herein and this motion is unopposed. The deadlines for J.C. Penney Company, which was incorrectly named in the Complaint, to conclude document production and serve privilege log are currently set for Corporation, Inc., is incorrectly named as a defendant in this case, which J.C. Penney Corporation, Inc. has disclosed in its Answer to the Complaint (Docket No. l7 I ) and its Initial Disclosures. To date, Plaintiff has not amended the Complaint substituting J.C. Penney Corporation, Inc. for J.C. Penney Company, Inc. as the correct defendant in this case. ANopposED MorroN FoR Exr°í,tstov oF TIME ro ' J.C. Penney Company, Inc. ("J.C. Penney Company"), the parent holding company of J.C. Penney Couprcr° Cpnr┐nv Dtscovenv PAGE I Dockets.Justia.com October 29,2010 and November 17, 2010, respectively (Docket Nos. 411 and 464). The parties have conferred and agreed that the deadlines for completion Company's document production and service of J.C. Penney of a privilege log, if any, should be extended to November 19, 2010 and December 3, 2010, respectively. Provided that Eolas properly names J.C. Penney Corporation in the Complaint, J.C, Penney Corporation has been diligently searching and extracting responsive documents. This extension is necessary because despite its effort, J.C. Penney Corporation had to employ outside resources to locate and extract electronically stored documents which caused unforeseen delay. Accordingly, J.C. Penney Corporation, provided that Eolas names it in the Complaint, respectfully requests that the Court grant this unopposed Motion and extend the specifţed document production and privilege log deadlines up to and including November 19,2010 and December 3, 2010, respectively. Dated: October 29,2010 Respectfully submitted, /s/ Jeffrev F. Yee GREENBERG TRAURIG LLP Jeffrey K. Joyner (admitted pro hac vice) iovnerilđstlaw.com Jeffrey F. Yee (admittedpro hac vice) veei(˛.ě"law.com 2450 Colorado Avenue, Suite 400E Santa Monica, California 90404 Telephone: (3 10) 586-7700 Facsimile: (3 10) 586-7800 UN,PPOSED MOTION FOR EXTENSION OF TIME TO COMPLETE C█NTNV DISCOV°NV PAGE 2 BUETIIERJOE & CARPENTER, LIrC Christopher M. Joe chris. i oe(đbi ciolaw. com Brian Carpenter brian.carpenterb@bj siplaw. oom Eric rW. Buether erlc.buethere@bj cip law. com 1700 Pacifis Suite 2390 Dallas, Texas 75201 Telephone : (21 4) 466-127 0 Facsimile: Ql 4) 635 -1842 ATTORNEYS T1OR DETENDAIYT J.C. PEI{NEY CORPORATION, INC. T]Nappospo MoTIoN FoR EKTENSIaN OF NME TO C¨MPL°rE CERTAIN DISCOVERY PAGE 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 Conrt's CN{/ECF system per Local Rule CV-5(aX3) on October 29,2010. Any other counsel of reaord will be served by first class mail on this same date. /s/,leffrev F Yee Jeffrey F. Yee Uí.Iopposso MonoN FoR ExrENsIoN oF TIME TO COMPLETE CERTAIN DISCOVERY PACE 4

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