Rosetta Stone LTD v. Google Inc.

Filing 31

MOTION to Compel Production of Documents by Rosetta Stone LTD. (Attachments: # 1 Proposed Order Proposed Order)(Ross, Terence)

Rosetta Stone LTD v. Google Inc.

Doc. 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division __________________________________________ ) ROSETTA STONE LTD., ) ) Plaint iff, ) ) ) -v) ) GOOGLE INC., ) ) Defendant. ) ) __________________________________________)

Case No. 1:09-cv-00736 (GBL/TCB)

ROSETTA STONE LTD.'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT GOOGLE INC. Pursuant to Rule 37 of the Federal Rules of Civil Procedure and Local Rule 37(A), Plaintiff Rosetta Stone Ltd. ("Rosetta Stone") respectfully moves this Court to compel the production of documents by Google Inc. ("Google") responsive to Rosetta Stone's First and Second Set of Requests for the Production of Documents. For the reasons set forth in the Memorandum of Points and Authorities filed simultaneously herewith, Rosetta Stone submits that the document production requests at issue are relevant to this lawsuit and that Google has no basis for withholding their production. In addition, pursuant to Local Rule 37(F), and as discussed in more detail in Rosetta Stone's Memorandum, Rosetta Stone hereby moves the Court to extend the cut-off date for the completion of fact discovery in this case to March 15, 2010, an extension of thirty-one (31) business days from the current date for completion of all fact discovery.

Dockets.Justia.co

Dated: January 8, 2010 ____________ /s/___________________ Terence P. Ross VSB # 26408 CROWELL & MORING, LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004 Phone: [phone] Fax: [phone] [e-mail] Counsel For Plaintiff, Rosetta Stone Ltd.