TimesLines, Inc v. Facebook, Inc.

Filing 71

NOTICE of Motion by Brendan J. Hughes for presentment of motion in limine 69 before Honorable John W. Darrah on 12/27/2012 at 09:30 AM. (Hughes, Brendan)

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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 NOTICE OF MOTION TO: All Counsel of Record as reflected in the Court’s CM/ECF system for this case. PLEASE TAKE NOTICE that on December 27, 2012 at 9:30 a.m., or as soon thereafter as counsel may be heard, the Parties will appear before the Honorable Judge John W. Darrah, or any judge sitting in his stead, in Courtroom 1203 of the United States District Court, 219 South Dearborn, Chicago, Illinois, and shall then and there present the contemporaneously-filed Motion to Exclude Dr. Eli Seggev’s Survey and Related Expert Report and Testimony. In addition, at the presentment hearing, Defendant Facebook, Inc. respectfully requests that the Court clarify that the parties’ deadline to file dispositive motions in this matter is January 31, 2013. The parties included that deadline in their Joint Initial Status Report. Further, during the January 24, 2012 hearing, it appeared that the Court had agreed to set January 31, 2013 as the deadline for filing dispositive motions. To date, however, the Court has not issued an order setting the deadline. // 1 Dated: December 19, 2012 Respectfully submitted,   COOLEY LLP By: /s/ Brendan J. Hughes Peter J. Willsey (pro hac vice) Brendan Hughes (pro hac vice) COOLEY LLP 777 6th Street, NW, Suite 1100 Washington, DC 20001 Tel: (202) 842-7800 Fax: (202) 842-7899 Email: pwillsey@cooley.com bhughes@cooley.com Michael G. Rhodes (pro hac vice) COOLEY LLP 101 California Street, 5th Floor San Francisco, CA 94111-5800 Tel: (415) 693-2000 Fax: (415) 693-2222 Email: rhodesmg@cooley.com Steven D. McCormick (#1824260) KIRKLAND & ELLIS LLP 300 North Lasalle Chicago, IL 60654-3406 Tel: (312) 862-2000 Fax: (312) 862-2200 Email: smccormick@kirkland.com Counsel for Facebook, Inc. 2 CERTIFICATE OF SERVICE The undersigned, an attorney, hereby certifies that he served the foregoing NOTICE OF MOTION by means of the Court’s CM/ECF System, which causes a true and correct copy of the same to be served electronically on all CM/ECF registered counsel of record, on December 19, 2012. Dated: December 19, 2012 /s/ Brendan J. Hughes Brendan J. Hughes (pro hac vice) COOLEY LLP 777 6th Street, NW, Suite 1100 Washington, DC 20001 Tel: (202) 842-7800 Fax: (202) 842-7899 Email: bhughes@cooley.com 180727 /DC 3