Illinois Computer Research, LLC v. Fish & Richardson, et al,

Filing 181

NOTICE of Motion by Raymond P. Niro for presentment of motion to strike,, motion for relief, #180 before Honorable Rebecca R. Pallmeyer on 6/3/2008 at 08:45 AM. (Niro, Raymond)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ILLINOIS COMPUTER RESEARCH, LLC., Plaintiff and Counterclaim Defendant, v. FISH & RICHARDSON P.C., Defendant, Counterclaimant, Third-Party Plaintiff and Counterclaim Defendant, v. SCOTT C. HARRIS, MEMORY CONTROL ENTERPRISE, LLC, BARTEX RESEARCH, LLC, INNOVATIVE BIOMETRIC TECHNOLOGY, LLC, PARKER INNOVATIVE TECHNOLOGIES, LLC, VIRGINIA INNOVATIVE TECHNOLOGY, LLC, INNOVATIVE PATENTED TECHNOLOGY, LLC AND ANY JOHN DOE SHELL ENTITIES, Third-Party Defendants. ) ) ) ) Civil Action No. 07 C 5081 ) ) ) Honorable Rebecca R. Pallmeyer ) Magistrate Judge Maria Valdez ) ) ) ) ) ) ) ) ) ) )

NOTICE OF MOTION TO: See attached Certificate of Service

PLEASE TAKE NOTICE that on Tuesday, June 3, 2008 at 8:45 a.m., counsel for Plaintiff will appear before the Honorable Rebecca R. Pallmeyer, or any judge sitting in her stead, in the Courtroom usually occupied by her, Room 2119, at the United States District Courthouse, 219 South Dearborn Chicago, Illinois, and then and there present ICR'S MOTION TO STRIKE FISH'S MEMORANDUM SUPPORTING ITS MOTION TO DISMISS, AND TO STRIKE ALL OTHER PLEADINGS THAT MAKE REFERENCE TO "SHELL ENTITIES" OR, IN THE ALTERNATIVE, TO REQUIRE FISH TO RE-FILE ALL SUCH PLEADINGS WITHOUT REFERENCE TO PEJORATIVE TERMS, a copy of which is attached.

Respectfully submitted, /s/ Raymond P. Niro Raymond P. Niro Paul K. Vickrey Richard B. Megley, Jr. Laura A. Kenneally Niro, Scavone, Haller & Niro 181 West Madison, Suite 4600 Chicago, Illinois 60602-4635 [phone] Fax: [phone] Attorneys for Illinois Computer Research, LLC and Scott C. Harris

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CERTIFICATION OF SERVICE The undersigned hereby certifies that a copy of the foregoing NOTICE OF MOTION was electronically filed with the Clerk of Court using CM/ECF system, which will send notification by electronic mail to the following: David J. Bradford - [e-mail];;; Eric A. Sacks - [e-mail] Daniel J. Weiss - [e-mail] Terrence J. Truax - [e-mail] Jenner & Block LLP 330 N. Wabash Avenue Chicago, IL 60611 [phone] Counsel for Fish & Richardson, P.C. on May 30, 2008. /s/ Raymond P. Niro