Rosetta Stone LTD v. Google Inc.
Filing
249
Consent MOTION to Amend/Correct Deadlines by Google Inc.. (Attachments: # 1 Exhibit A)(Cobb, Stephen)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
ROSETTA STONE LTD.
Plaintiff,
CIVIL ACTION NO. 1:09cv736
(GBL / TCB)
v.
GOOGLE INC.
Defendant.
CONSENT MOTION TO ALTER OR AMEND DEADLINES
COMES NOW Defendant Google Inc., by counsel, pursuant to the Federal Rules of Civil
Procedure, and files this Consent Motion to Alter or Amend Deadlines, setting forth the
following:
1.
On July 17, 2012, the Honorable Theresa Carol Buchanan entered a Scheduling
Order (Dkt. No. 248) adopting the parties’ Joint Discovery Plan (Dkt. No. 247).
2.
As part of the Joint Discovery Plan, certain deadlines were adopted for Defendant
Google’s filing of Motions in Limine. Specifically, the parties agreed that the Motions in Limine
were to be filed by August 10, 2012, Oppositions to be filed by August 17, 2012, and Replies (if
any) to be filed by August 22, 2012. As part of the Joint Discovery Plan, the Motions in Limine
were to be heard on August 31, 2012.
3.
The parties have agreed to alter the filing deadlines as follows: Motions in Limine
to be filed by August 15, 2012, Oppositions to be filed by August 24, 2012, and Replies (if any)
to be filed by August 29, 2012.
4.
The hearing date will remain unchanged unless otherwise agreed by the parties
and approved by the Court.
5.
All other deadlines will remain unchanged unless agreed by the parties and
approved by the Court.
WHEREFORE, in consideration of the foregoing the parties respectfully request that the
Court enter the Proposed Consent Order attached hereto as Exhibit A and grant them such other
and further relief as the Court deems just and appropriate.
Respectfully Submitted,
GOOGLE INC.
By counsel
/s/
Jonathan D. Frieden, Esquire (VSB No. 41452)
Stephen A. Cobb, Esquire (VSB No. 75876)
ODIN, FELDMAN & PITTLEMAN, P.C.
9302 Lee Highway, Suite 1100
Fairfax, Virginia 22031
(703) 218-2100
(703) 218-2160 (facsimile)
jonathan.frieden@ofplaw.com
stephen.cobb@ofplaw.com
Margret M. Caruso, Esquire (Admitted Pro Hac Vice)
QUINN, EMANUEL, URQUHART, OLIVER & HEDGES, LLP
555 Twin Dolphin Drive, Suite 560
Redwood Shores, California 94065
(650) 801-5101
(650) 801-5100 (facsimile)
margretcaruso@quinnemanuel.com
Counsel for Defendant Google Inc.
SEEN AND AGREED
/s/
Warren Thomas Allen, II
Clifford M. Sloan
Jennifer L. Spaziano
SKADDEN ARPS SLATE MEAGHER & FLOM LLP
1440 New York Ave NW
Washington, DC 20005-2111
202-371-7126
202-661-9063 (facsimile)
wtallen@skadden.com
cliff.sloan@skadden.com
jen.spaziano@skadden.com
Counsel for Plaintiff Rosetta Stone Ltd.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of August, 2012, I will electronically file the
foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification
of such filing (NEF) to the following:
Warren Thomas Allen, II
SKADDEN ARPS SLATE MEAGHER & FLOM LLP
1440 New York Ave NW
Washington, DC 20005-2111
202-371-7126
202-661-9063 (facsimile)
wtallen@skadden.com
Counsel for Plaintiff Rosetta Stone Ltd.
/s/
Jonathan D. Frieden, Esquire (VSB No. 41452)
Stephen A. Cobb, Esquire (VSB No. 75876)
ODIN, FELDMAN & PITTLEMAN, P.C.
9302 Lee Highway, Suite 1100
Fairfax, Virginia 22031
(703) 218-2100
(703) 218-2160 (facsimile)
jonathan.frieden@ofplaw.com
stephen.cobb@ofplaw.com
Counsel for Defendant Google Inc.
#1765774v1
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