Free Motion to Reset - District Court of Colorado - Colorado

Case 1:03-cv-02579-RPM

Document 125

Filed 11/14/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-02579-RPM-BNB VARCO, L.P., Plaintiff, vs. PASON SYSTEMS USA CORP., Defendant. PLAINTIFF'S UNOPPOSED MOTION TO RESCHEDULE FINAL PRETRIAL CONFERENCE Plaintiff Varco L.P. ("Varco") respectfully requests that the Final Pretrial Conference, currently set for Friday, November 17, 2006, be vacated and rescheduled for another date in approximately 30 days, dependent upon the Court's availability. Varco further respectfully requests that the hearing on pending motions, which is also set on November 17, 2006 at 2:00 p.m., proceed as scheduled. In support of this unopposed motion, Varco asserts as follows: 1. The trial of this patent infringement matter will require the presentation of

complex, technical evidence to a jury. 2. Within the past several weeks, Defendant Pason Systems USA Corp. ("Pason")

belatedly produced over 12,000 pages of documents in response to Varco's prior discovery requests. Some of the documents were produced as late as a week ago. Varco has been unable to review all of these recently produced documents and determine which of them should be listed as trial exhibits.

Case 1:03-cv-02579-RPM

Document 125

Filed 11/14/2006

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3.

For these reasons, the parties require additional time to complete the proposed

Final Pretrial Order, which is due on November 15, 2006. 4. Pursuant to D.C. Colo. L. Civ. R 7.1(A), the undersigned counsel certifies that she

has conferred with counsel for Defendant Pason and is authorized to state that Pason does not oppose this motion. 5. Pursuant to D.C. Colo. L. Civ. R. 6.1(D), counsel for Varco certifies that a copy

of this Motion has been served on the client. WHEREFORE, Plaintiff Varco respectfully requests that the Final Pretrial Conference, currently set for Friday, November 17, 2006, be vacated and rescheduled for a date in midDecember, 2006 or as soon thereafter as the Court's calendar permits. Further, Varco respectfully requests that the hearing on pending motions proceed as currently scheduled on Friday, November 17, 2006 at 2:00 p.m. Dated: November 14, 2006 Respectfully submitted, s/ Jane Michaels Jane Michaels Joseph T. Jaros Ryan T. Bergsieker Holland & Hart LLP 555 Seventeenth Street, Suite 3200 Post Office Box 8749 Denver, Colorado 80201-8749 Tel. (303) 295-8000 Fax (303) 295-8261 [email protected] [email protected] [email protected]

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Case 1:03-cv-02579-RPM

Document 125

Filed 11/14/2006

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Guy E. Matthews Robert M. Bowick MATTHEWS, LAWSON, BOWICK & AL-AZEM, PLLC 2000 Bering Drive, Suite 700 Houston, Texas 77057 Tel. (713) 355-4200 Fax (713) 355-9689 [email protected] [email protected] ATTORNEYS FOR PLAINTIFF VARCO, L.P.

CERTIFICATE OF SERVICE I hereby certify that, on November 14, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: [email protected] [email protected] s/ Jane Michaels

I also certify that, on November 14, 2006, I served a true and correct copy of the foregoing to plaintiff Varco by: U.S. Mail, postage prepaid Hand Delivery Fax Cormac Creaven, Esq. National Oilwell Varco 10000 Richmond Avenue PO Box 4888 Houston, TX 77210 s/ Jane Michaels
3631978_2.DOC

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