Huon v. Breaking Media et al

Filing 36

MOTION by Defendants Abovethelaw.com, Breaking Media, Breakingmedia.com, David Lat, John Lerner, David Minkin, Elie Mystal for leave to file excess pages - Unopposed (Attachments: # 1 Exhibit 1 (Memo iso mtd), # 2 Exhibit A to Exhibit 1, # 3 Exhibit B to Exhibit 1)(Mandell, Steven)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS - EASTERN DIVISION
MEANITH HUON,
Plaintiff,
v.
ABOVETHELAW.COM et al.,
Defendants.

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Case No. 11-cv-03054
Judge Aspen
Magistrate Judge Gilbert

DEFENDANTS’ UNOPPOSED MOTION FOR LEAVE
TO FILE BRIEF IN EXCESS OF FIFTEEN PAGES
Defendants Breaking Media, LLC (erroneously sued as AboveTheLaw.com,
BreakingMedia.com, and Breaking Media), David Lat, Elie Mystal, John Lerner, and David
Minkin (the “ATL Defendants”) respectfully request that the Court grant them leave to file their
memorandum in support of their motion to dismiss (“Memorandum”), which exceeds the 15page limit established by Local Rule 7.1.
1.

The ATL Defendants have endeavored to use the minimum number of pages

necessary to present their various arguments concerning Plaintiff’s numerous factual and legal
contentions.
2.

Plaintiff’s complaint includes six theories of recovery based on approximately

forty alleged statements. The ATL Defendants have attached a summary chart to the
Memorandum that indicates which of their arguments apply to each of the alleged statements.
The chart is six pages long and the remainder of the Memorandum is twelve pages long, for a
total of eighteen pages.
3.

The Memorandum is attached hereto as Exhibit 1. The Memorandum includes a

table of contents and table of cases, as required by Local Rule 7.1.

4.

Plaintiff has agreed not to oppose this request.

WHEREFORE, the ATL Defendants respectfully request that this Court permit them to
file the Memorandum.
Dated: September 21, 2011

Respectfully submitted,
BREAKING MEDIA, LLC (erroneously sued as
AboveTheLaw.com, BreakingMedia.com, and
Breaking Media), DAVID LAT, ELIE MYSTAL,
JOHN LERNER, AND DAVID MINKIN
By:

Steven P. Mandell (ARDC #6183729)
Steven L. Baron (ARDC #6200868)
Sharon R. Albrecht (ARDC #6288927)
MANDELL MENKES LLC
One North Franklin, Suite 3600
Chicago, IL 60606
[phone]
188004

/s/ Steven P. Mandell
One of their attorneys

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