New Pacer--IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
Technology Properties Limited and Patriot
Scientific Corporation,
Plaintiffs,
vs.
Matsushita Electric Industrial Co., Ltd.,
Panasonic Corporation of North America,
JVC Americas Corporation, NEC
Corporation, NEC Electronics America, Inc.,
NEC Corporation of America, NEC Display
Solutions of America, Inc., NEC Unified
Solutions, Inc., Toshiba Corporation, Toshiba
America, Inc., Toshiba America Electronic
Components, Inc., Toshiba America
Information Systems, Inc., Toshiba America
Consumer Products, LLC.
Defendants.
JURY TRIAL DEMANDED
PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO NOTIFY THE
COURT AS TO PRIVILEGED DOCUMENT DISPUTES
Case 2:05-cv-00494-TJW Document 195-1 Filed 02/09/2007 Page 1 of
COMES NOW, Plaintiffs, Technology Properties Limited and Patriot Scientific Corporation, seeking the Court\'s extension of the deadline to notify the Court whether disputes exist as to claims of privileged documents from February 8, 2007 to March 9, 2007.
This extension is not being sought for the purpose of delay, but because the parties are addressing complicated issues concerning documents from prior litigations and the application of foreign law to privilege issues, and hope to narrow or eliminate the issues that must be decided by the Court. Defendants have agreed to this motion. WHEREFORE, Plaintiffs respectfully pray that the Court grant this Motion and permit the above extension.
DATED: February 9, 2007 Respectfully submitted,
By: /s Iris Sockel Mitrakos
TOWNSEND and TOWNSEND and CREW LLP
Iris Sockel Mitrakos, CA State Bar No. 190162
CERTIFICATE OF SERVICE
I hereby certify that on February 9, 2007 Plaintiffs’ Unopposed Motion For Extension Of Time To Notify The Court As To Privileged Document Disputes and Order Granting Plaintiffs’
Unopposed Motion For Extension Of Time To Notify The Court As To Privileged Document Disputes were served electronically with a copy of these documents via the Court’s CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date.
/s/ Iris Sockel Mitrakos______
IRIS SOCKEL MITRAKOS
CERTIFICATE OF CONFERENCE
Counsel for Plaintiffs has discussed the above motion with counsel for the Toshiba Defendants, the MEI Defendants, the NEC Defendants and with the ARM Defendants on February 9, 2007, and all counsel have indicated they are in agreement with this Motion.
/s/ Iris Sockel Mitrakos______
IRIS SOCKEL MITRAKOS