`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`Civil Action No. 2:14-cv-0061-JRG-RSP
`
`JURY TRIAL DEMANDED
`
`ContentGuard Holdings, Inc.,
`
`
`
`
`Plaintiff,
`
`-against-
`
`
`
`Google Inc.
`
`
`Defendant.
`
`
`
`
`
`
`
`
`
`
`
`
`JOINT MOTION FOR AN ORDER EXTENDING RESPONSE DATES
`
`On February 19, 2014, Plaintiff filed a Motion to Consolidate, seeking an order
`
`consolidating this case with a co-pending patent infringement action. (Dkt. 14.) On February
`
`20, 2014, Defendant filed a Motion to Stay and/or Transfer, seeking an order staying this case in
`
`favor of another a litigation pending in the Northern District of California and/or transfer of this
`
`case to the Northern District of California. (Dkt. 15.)
`
`To fully respond to the Motion to Stay and/or Transfer, Plaintiff has requested that
`
`Defendant extend the date of Plaintiff’s response to March 14, 2014. Plaintiff offered a similar
`
`courtesy with respect to Defendant’s response to the Motion to Consolidate.
`
`The parties respectfully request an order extending both response dates to March 14,
`
`2014.
`
`McKool 452991v1
`
`-1-
`
`
`
`Case 2:14-cv-00061-JRG-RSP Document 17 Filed 02/25/14 Page 2 of 3 PageID #: 568
`
`
`Date: February 25, 2014.
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ J. Mark Mann /with permission
`
`J. Mark Mann
`State Bar No. 12926150
`mark@themannfirm.com
`Mann, Mindel, Thompson
`300 West Main Street
`Henderson, Texas 75652
`Telephone: (903) 657-8540
`Facsimie: (903) 657-6003
`
`ATTORNEYS FOR DEFENDANT
`GOOGLE INC.
`
`/s/ Sam Baxter
`
`Sam Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 East Houston, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`Robert A. Cote
`rcote@mckoolsmith.com
`MCKOOL SMITH, P.C.
`One Bryant Park, 47th Floor
`New York, New York 10036
`Telephone: (212) 402-9400
`Facsimile: (212) 402-9444
`
`
`
`
`
`
`
`ATTORNEYS FOR
`CONTENTGUARD HOLDINGS, INC.
`
`McKool 452991v1
`
`-2-
`
`
`
`Case 2:14-cv-00061-JRG-RSP Document 17 Filed 02/25/14 Page 3 of 3 PageID #: 569
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was filed electronically in
`compliance with Local Rule CV-5(a). As such, this document was served on all counsel who
`have consented to electronic services on this the 25th day of July, 2014. Local Rule CV-
`5(a)(3)(A).
`
`
`
`
`
`
`
`
`
`
`
` /s/ Radu A. Lelutiu
`
`Radu A. Lelutiu
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF CONFERENCE
`
`The Parties have conferred and have agreed to the joint filing of this motion.
`
`
`
`McKool 452991v1
`
`-3-
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
