Vulcan Golf, LLC v. Google Inc. et al

Filing 64

MOTION by Defendant Oversee.Net for leave to file excess pages (AGREED) (Carter, Janelle)

Vulcan Golf, LLC v. Google Inc. et al

Doc. 64

Case 1:07-cv-03371

Document 64

Filed 08/13/2007

Page 1 of 4

UNITES STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC, Individually And On Behalf of All Others Similarly Situated, ) ) ) ) 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 Charles P. Kocoras Magistrate Judge Geraldine Soat Brown

AGREED MOTION OF DEFENDANT OVERSEE.NET FOR LEAVE TO FILE BRIEFS IN EXCESS OF PAGE LIMITATION With Plaintiff's consent, Defendant OVERSEE.NET ("Oversee") moves the Court for leave to file a Memorandum In Support Of Its Motion To Dismiss the Complaint in excess of the page limit stated in Rule 7.1 of the Local Rules for the Northern District of Illinois, up to thirty pages. 1. In support of its Motion to Dismiss, Oversee's brief addresses all twelve counts of the 121-page Complaint filed by Plaintiff against Oversee and the other defendants. 2. By its nature, Oversee's brief must address multiple legal standards and explain why, under those standards, all twelve counts should be dismissed against Oversee. 3. Moreover, the total length of Oversee'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.

Dockets.Justia.com

Case 1:07-cv-03371

Document 64

Filed 08/13/2007

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4. Plaintiff consents to this motion. Further, Oversee and Plaintiff have mutually consented that Plaintiff may file a brief of up to thirty pages in response to Oversee's Motion To Dismiss, and Oversee may file a reply brief of up to fifteen pages. 5. Oversee brings this motion in good faith and submits that granting it will serve the interests of justice. Wherefore, Oversee requests that this Court enter an order granting: (1) Oversee leave to file a brief of up to thirty pages in support of its Motion To Dismiss; (2) Plaintiff leave to file a brief of up to thirty pages in response to Oversee's Motion To Dismiss; and (3) Oversee leave to file a reply brief of up to fifteen pages.

Case 1:07-cv-03371

Document 64

Filed 08/13/2007

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Date:

August 10, 2007

Respectfully Submitted, WINSTON & STRAWN LLP By: s/Janelle M. Carter____ One of Their Attorneys

Ronald Y. Rothstein Janelle M. Carter Winston & Strawn LLP 35 West Wacker Drive Chicago, Illinois 60601 Tel: [phone] Fax: [phone] Email: [e-mail] Steven Atlee Winston & Strawn LLP 333 Grand Avenue Los Angeles, CA 90071 Tel: [phone] Fax: [phone] Pro Hac Vice Application Pending Andrew Bridges Winston & Strawn LLP 101 California Street San Francisco, CA 94111 Tel: [phone] Fax: [phone] Admission Pending

Case 1:07-cv-03371

Document 64

Filed 08/13/2007

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CERTIFICATE OF SERVICE I hereby certify that on August 10, 2007, a true and correct copy of the foregoing was served in accordance with Rule 5, Federal Rules of Civil Procedure, on the following: Robert M. Foote Stephen William Fung Foote, Meyers, Mielke & Flowers, LLC 28 North First Street, #2 Geneva, Illinois 60134 Jonathan M. Cyrluk Mariah E. Moran Stetler & Duffy, Ltd. 11 South LaSalle Street, Suite 1200 Chicago, Illinois 60603 Jeffrey Singer Misty Rose Martin Segal, McCambridge, Singer & Mahoney, Ltd. 330 North Wabash Avenue, Suite 200 Chicago, Illinois 60611 Alexis Elizabeth Payne Bradley Louis Cohn Brett A. August Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP 311 South Wacker Drive, Suite 5000 Chicago, Illinois 60606 Steven R. Borgman Vinson & Elkins LLP 2500 First City Tower 1001 Fannin Street Houston, Texas 77002 Kathleen Currie Chavez Chavez Law Firm P.C. 28 North First Street, #2 Geneva, Illinois 60134 Joseph Gratz Michael Page Keker & Van Nest LLP 710 Sansome Street San Francisco, California Alison C. Conlon Michael R. Dockterman Wildman, Harrold, Allen & Dixon 225 West Wacker Drive, Suite 3000 Chicago, Illinois 60606 Scott Ryan Hiehle Vinson & Elkins LLP Trammel Crow Center 2001 Ross Avenue, Suite 3700 Dallas, Texas 75201

___s/ Janelle M. Carter__