TimesLines, Inc v. Facebook, Inc.

Filing 166

MOTION by Plaintiff TimesLines, Inc for leave to file Instanter the Attached Supplemental Authority in Support of Timelines, Inc.'s Motion in Limine No. 7 (Attachments: # 1 Exhibit A - Supplemental Authority)(Van Baren, Bruce)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TIMELINES, INC. Plaintiff, v. FACEBOOK, INC. Defendant. ) ) ) ) ) ) ) ) ) Civil Action No.: 11 CV 6867 HONORABLE JOHN W. DARRAH Jury Trial Demanded TIMELINES, INC.’S MOTION FOR LEAVE TO FILE INSTANTER THE ATTACHED SUPPLEMENTAL AUTHORITY IN SUPPORT OF TIMELINES’ MOTION IN LIMINE NO. 7 Plaintiff Timelines, Inc., through its attorneys, Reed Smith LLP, moves this Court for leave to file Instanter the attached supplemental authority in support of Timelines’ Motion In Limine No. 7. for the reasons set forth below. 1. At the Pre-Trial Conference on April 18, 2013, the Court took under advisement Timelines’ Motion In Limine No. 7. 2. Timelines now seeks to bring to the Court’s attention the supplemental authority—as case from the Northern District of Illinois—attached hereto as Exhibit A, which is relevant and helpful to the point of law at issue in Timelines’ Motion in Limine No. 7. See Jacobs, Jr. v. Guardian Life Ins. Co. of Am., 730 F. Supp. 2d 830, 844 (N.D. Ill. 2010) (“Because the Court finds the supplemental authority helpful with respect to this point of law, it grants Defendants’ Motion for Leave to File Supplemental Authority.”). 3. For these reasons, Timelines Inc. respectfully request that the Court grant this Motion For Leave to File Instanter the Attached Supplemental Authority. Dated: April 18, 2013 Respectfully submitted, TIMELINES, INC., Plaintiff/Counter-Defendant By: /s/ Douglas A. Albritton______ James T. Hultquist (SBN 6204320) Douglas A. Albritton (SBN 6228734) Michael L. DeMarino (SBN 6298337) Bruce R. Van Baren (SBN 6310375) REED SMITH LLP 10 South Wacker Drive Chicago, IL 60606-7507 312-207-1000 Counsel for TIMELINES, INC. 2 CERTIFICATE OF SERVICE I, the undersigned attorney, certify that I electronically filed the attached document. Pursuant to Rule 5(b)(3) of the Federal Rules of Civil Procedure and Local Rule 5.9, I have thereby electronically served all Filing Users. April 18, 2013 Respectfully submitted, TIMELINES, INC., Plaintiff/Counter-Defendant By: /s/ Douglas A. Albritton James T. Hultquist (SBN 6204320) Douglas A. Albritton (SBN 6228734) Michael L. DeMarino (SBN 6298337) Bruce R. Van Baren (SBN 6310375) REED SMITH LLP 10 South Wacker Drive Chicago, IL 60606-7507 Telephone: +1 312 207 1000 Facsimile: +1 312 207 6400 Counsel for TIMELINES, INC. 3