Vulcan Golf, LLC v. Google Inc. et al

Filing 57

MOTION by Defendant Google Inc. for leave to file excess pages (Agreed) (Moran, Mariah)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 57 Case 1:07-cv-03371 Document 57 Filed 08/10/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC., Individually and on behalf of all Others Similarly Situated, Lead Plaintiff, 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. ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 07 CV 3371 Judge Kocoras Magistrate Judge Brown AGREED MOTION FOR LEAVE TO FILE BRIEF IN EXCESS OF PAGE LIMITATION Defendant Google, Inc. ("Google"), by and through its attorneys, respectfully requests the Court to enter an order granting Google leave to file a Memorandum in Support of Its Motion to Dismiss the Complaint in excess of the page limitation stated in Rule 7.1 of the Local Rules for the Northern District of Illinois. In support of this motion, Google states as follows: 1. In support of its Motion to Dismiss, Google's supporting memorandum will address all twelve counts of the 121-page Complaint filed against Google and the other defendants. 2. In order to sufficiently respond to the Complaint, Google must address the multiple legal standards and explain why, under those standards, each of the twelve counts contained in the Complaint should be dismissed as to Google. Moreover, the total length of Google's brief will be far less than the combined page total that would be allowed if separate motions were filed to dismiss each of the twelve counts. 3. Given the extraordinary size of the Complaint and the nature of the claims raised Case 1:07-cv-03371 Document 57 Filed 08/10/2007 Page 2 of 2 therein, Google respectfully submits that it will need up to thirty pages to adequately address the reasons the Court should dismiss the Complaint in its entirety against Google. 4. Plaintiff's counsel has been apprised of the basis of this motion and agrees to the terms set forth herein. Further, Google and Plaintiff have mutually consented that Plaintiff may seek leave to file a response brief of up to thirty pages in response to Google's Motion to Dismiss, and Google may file a reply brief of up to fifteen pages. 5. Google brings this motion in good faith and submits that granting it will serve the interests of justice. WHEREFORE, for the foregoing reasons, Defendant Google, Inc., respectfully requests that the Court enter an order granting Google leave to file a brief of up to thirty (30) pages in support of its Motion to Dismiss and such other and further relief as the Court deems just and proper. Respectfully submitted, GOOGLE, INC. By: /s/ Mariah E. Moran One of Its Attorneys Michael H. Page Joseph Gratz Keker & Van Nest, LLP San Francisco, CA 94111 (415) 391-5400 Lead Counsel Admitted Pro Hac Vice Joseph J. Duffy Jonathan M. Cyrluk Mariah E.Moran STETLER & DUFFY, LTD. 11 South LaSalle Street, Suite 1200 Chicago, IL 60603 (312) 338-0200 2

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