Vulcan Golf, LLC v. Google Inc. et al

Filing 218

MOTION by Plaintiffs John B. Sanfilippo & Son, Inc., Blitz Realty Group, Inc., Vincent E Jackson, Vulcan Golf, LLC for leave to file excess pages (Foote, Robert)

Vulcan Golf, LLC v. Google Inc. et al

Doc. 218

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 REPLY 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 Reply Brief in Excess of Fifteen Pages, state as follows: 1. On August 21, 2008, Plaintiffs filed their Motion for Class Certification and

accompanying Motion for Leave to File Instanter Brief in Excess of Fifteen Pages. 2. On September 4, 2008 this Court granted Plaintiffs' Motion for Leave to File

Instanter Brief in Excess of Fifteen Pages in Excess of Fifteen Pages, allowing Plaintiffs to file a brief not in excess of thirty-five (35) pages. 3. On September 10, 2008, Defendants filed their Motion for Leave to File

Defendants' Opposition to Plaintiffs' Motion for Class Certification in Excess of Page

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Limitation. 4. On September 15, 2008 this Court granted Defendants' Motion for Leave to File

Defendants' Opposition to Plaintiffs' Motion for Class Certification in Excess of Page Limitation, allowing Defendants to file a brief not in excess of thirty-five (35) pages. 5. Plaintiffs will require additional pages to properly reply to all arguments raised by

Defendants in their thirty-five (35) page Brief in Opposition to Plaintiffs' Motion for Class Certification. 6. length. 7. Plaintiffs have made a good faith effort to stay within the page limitations set by Plaintiffs intend to file a reply brief not exceeding twenty-eight (28) pages in

Northern District of Illinois Local Rule 7.1, but the complexity of this matter necessitates a brief longer than fifteen (15) pages. 8. Accordingly, Plaintiffs request leave to file a twenty-eight (28) page reply brief in

regards to their Motion for Class Certification. 9. Plaintiffs file this Motion in accordance with the United States District Court,

Northern District of Illinois Local Rule 7.1. 10. Defendants would not be unfairly prejudiced by the Court granting Plaintiffs

leave to file a reply brief totaling twenty-eight (28) pages. 11. Counsel for all Defendants have indicated they do not oppose the requested relief.

WHEREFORE, Plaintiffs hereby move this Honorable Court to enter an Order allowing the following relief: 1. Granting leave to Plaintiff to file a reply brief in regards to its Motion for Class Certification totaling twenty-eight (28) pages, instanter; and Any other relief as appropriate and just.

2.

Dated: September 25, 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 September 25, 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] R. Adam Lauridsen [e-mail] Vincent V. Carissimi [e-mail] Robert J. Hickok [e-mail] Daralyn J. Durie [e-mail]

/s/Robert M. Foote