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Case 3:08-cv-03343-SI Document 62 Filed 12/05/2008 Page 1 of 3

1 I. NEEL CHATTERJEE (STATE BAR NO. 173985)


nchatterjee@orrick.com
2 DEBORAH E. FISHMAN (STATE BAR NO. 197584)
dfishman@orrick.com
3 ROBERT W. RICKETSON (STATE BAR NO. 148481)
rricketson@orrick.com
4 ORRICK, HERRINGTON & SUTCLIFFE LLP
1000 Marsh Road
5 Menlo Park, CA 94025
Telephone: +1-650-614-7400
6 Facsimile: +1-650-614-7401
7 Attorneys for Defendant
NVIDIA Corporation
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9 UNITED STATES DISTRICT COURT

10 NORTHERN DISTRICT OF CALIFORNIA

11 SAN FRANCISCO DIVISION

12

13 RAMBUS, INC., Case No. C-08-03343 SI

14 Plaintiff, MOTION TO SHORTEN TIME FOR


BRIEFING AND SUBMITTING
15 v. MOTION TO STAY

16 NVIDIA CORPORATION, (CIVIL LOCAL RULE 6-3)

17 Defendant. Date: N.A.


Time: N.A.
18 Judge: The Hon. Susan Illston

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MOTION TO SHORTEN TIME FOR BRIEFING AND
OHS West:260560852.2
SUBMITTING MOTION TO STAY
15075-2017 R23/INC C-08-03343 SI
Case 3:08-cv-03343-SI Document 62 Filed 12/05/2008 Page 2 of 3

1 Pursuant to Civil Local Rule 6-3 defendant NVIDIA Corporation hereby respectfully
2 requests an order compressing the time for briefing its motion to stay this action (filed on
3 December 4, 2008, Docket No. 60) and providing that the matter will be submitted for decision
4 without oral argument, pursuant to Civil Local Rule 7-1 (b).
5 NVIDIA seeks an order requiring opposition to the stay motion to be filed by December
6 17, 2008 (thereby compressing the response time by only two days), with NVIDIA’s reply to be
7 filed on the third business day thereafter, December 22, 2008. NVIDIA further requests that the
8 matter then be decided on the papers expeditiously without a hearing due to impending deadlines,
9 including a Case Management conference.
10 Good cause exists for granting this relief because the date for NVIDIA’s Answer is
11 presently set for January 16, 2009, and the initial CMC is set for January 30, 2009. Requiring
12 NVIDIA to prepare an Answer, and requiring the parties and the Court to prepare for and to
13 engage in case management proceedings before the Court may consider the motion to stay would
14 undermine the very purposes served by a stay of this action, which are described more fully in the
15 stay motion.
16 NVIDIA sought to obtain Rambus’s stipulation to expedited briefing and submission of
17 the stay motion as shown in the declaration of Robert W. Ricketson submitted herewith, but
18 Rambus declined to do so.
19 The dates NVIDIA is requesting were selected with consideration of the Court’s calendar
20 and the holidays, and were designed to minimize the impact to Rambus (shortening its response
21 time by only two days) while still maximizing the possibility that the Court will have sufficient
22 time to consider the merits of the stay motion before NVIDIA’s answer is due and further efforts
23 towards preparing for the CMC would have to take place. NVIDIA has no objection, however, if
24 the Court would prefer to extend those upcoming deadlines rather than accelerate consideration of
25 the motion to stay.
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MOTION TO SHORTEN TIME FOR BRIEFING AND
OHS West:260560852.2
15075-2017 R23/INC
-2- SUBMITTING MOTION TO STAY
C-08-03343 SI
Case 3:08-cv-03343-SI Document 62 Filed 12/05/2008 Page 3 of 3

1 Dated: December 5, 2008 ORRICK, HERRINGTON & SUTCLIFFE LLP


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3 /s/ Robert W. Ricketson /s/


Robert W. Ricketson
4 Attorneys for Defendant
NVIDIA CORPORATION
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MOTION TO SHORTEN TIME FOR BRIEFING AND
OHS West:260560852.2 -3- SUBMITTING MOTION TO STAY
15075-2017 R23/INC C-08-03343

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