Vulcan Golf, LLC v. Google Inc. et al

Filing 199

MOTION by Plaintiff Vulcan Golf, LLC for leave to file excess pages Instanter (Foote, Robert)

Vulcan Golf, LLC v. Google Inc. et al

Doc. 199

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC, JOHN B. SANFILIPPO & SON, INC., BLITZ REALTYGROUP, INC., and VINCENT E. "BO" JACKSON, Individually and on Behalf of All Others Similarly Situated, Lead Plaintiffs, v. GOOGLE INC., OVERSEE.NET, SEDO LLC, DOTSTER, INC., AKA REVENUEDIRECT.COM, INTERNET REIT, INC. d/b/a IREIT, INC., and JOHN DOES I-X, Defendants. § § § § § § § § § § § § § § § § § §

Civil Action No. 07 CV 3371

Honorable Blanche M. Manning

PLAINTIFFS' UNOPPOSED MOTION FOR LEAVE TO FILE INSTANTER BRIEF IN EXCESS OF FIFTEEN PAGES NOW COME Plaintiffs, Vulcan Golf, LLC, John B. SanFilippo & Son, Inc., Blitz Realty Group, Inc., and Vincent E. "Bo" Jackson, by and through their attorneys, and for their Motion for Leave to File Instanter Brief in Excess of Fifteen Pages, state as follows: 1. On July 31, 2008, this Court ordered Plaintiff to file their Motion for Class

Certification by August 21, 2008. 2. On July 31, 2008, this Court ordered Defendants to file one consolidated response

to Plaintiff's Motion for Class Certification within twenty-one (21) days of Plaintiffs' filing of their Motion for Class Certification. 3. Plaintiffs will require additional pages to properly address their arguments for

class certification. Plaintiffs intend to file a brief totaling thirty-five (35) pages in length.

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4.

Plaintiffs have made a good faith effort to stay within the page limitations set by

Northern District of Illinois Local Rule 7.1, but the complexity of this matter necessitates a brief longer than fifteen (15) pages. 5. Accordingly, Plaintiffs request leave to file a thirty-five (35) page brief in support

of their Motion for Class Certification. 6. Plaintiffs file this Motion in accordance with the United States District Court,

Northern District of Illinois Local Rule 7.1. 7. Defendants would not be unfairly prejudiced by the Court granting Plaintiffs

leave to file a brief totaling thirty-five (35) pages. 8. relief. WHEREFORE, Plaintiffs hereby move this Honorable Court to enter an Order allowing the following relief: 1. Granting leave to Plaintiff to file a brief in support of its Motion for Class Certification totaling thirty-five (35) pages, instanter; and Any other relief as appropriate and just. Counsel for all Defendants have indicated they do not object to the requested

2.

Dated: August 21, 2008

FOOTE, MEYERS, MIELKE & FLOWERS, LLC

By:

/s/ Robert M. Foote Robert M. Foote, Esq. Craig S. Mielke, Esq. Matthew J. Herman, Esq. Stephen W. Fung, Esq. Mark A. Bulgarelli, Esq. Foote, Meyers, Mielke & Flowers, LLC 28 North First St., Suite 2 Geneva, IL 60134 Tel. No.: [phone]

Kathleen C. Chavez, Esq. Chavez Law Firm, P.C. 28 North First St., Suite 2 Geneva, IL 60134 William J. Harte, Esq. Dana Pesha, Esq. William J. Harte, Ltd. 111 West Washington Street, Suite 1100 Chicago, IL 60602 Benjamin G. Edelman, Esq. Law Office of Benjamin Edelman 27a Linnaean Street Cambridge, MA 02138 Tel. No.: [phone] Bryan L. Clobes, Esq. Cafferty Faucher, LLP 1717 Arch Street Suite 3610 Philadelphia, PA 19103 Nyran Rose Pearson, Esq. Dom J. Rizzi, Esq. Cafferty Faucher LLP 30 North LaSalle Street Suite 3200 Chicago, IL 60602 Attorneys for Plaintiffs

CERTIFICATE OF SERVICE I hereby certify that on August 21, 2008, I electronically filed the foregoing document with the clerk of court for the U. S. District Court, Northern District of Illinois, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the following attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means:

Brett A. August [e-mail] Michael H. Page [e-mail] Mariah Moran [e-mail] [e-mail] Janelle M. Carter [e-mail] [e-mail] Alison Conlon [e-mail] [e-mail] [e-mail] Joseph Gratz [e-mail] Alexis Payne [e-mail] Jeffrey Singer [e-mail] Anastasios Foukas [e-mail] Michael R. Dockterman [e-mail] [e-mail] [e-mail]

Kenneth P. Held [e-mail] Steven Borgman [e-mail] [e-mail] [e-mail] [e-mail]

Bradley L. Cohn [e-mail]

Jonathan M. Cyrluk [e-mail] [e-mail]

Misty Martin [e-mail] Ronald Rothstein [e-mail] [e-mail] [e-mail]

Scott R. Wiehle [e-mail] Joseph Duffy [e-mail] [e-mail] [e-mail]

William J. Harte [e-mail] [e-mail] Scott Ryan Wiehle [e-mail]

Dana Marie Pesha [e-mail] [e-mail] Aaron Van Oort [e-mail]

I certify that I have served the foregoing document by emailing a copy to the following individuals: Steven Atlee [e-mail] Joanna J. Cline [e-mail] Vincent V. Carissimi [e-mail] Robert J. Hickok [e-mail]

/s/Robert M. Foote