TimesLines, Inc v. Facebook, Inc.

Filing 102

MOTION by Plaintiff TimesLines, Inc for leave to file Additional Facts in its Local Rule 56.1(b)(3)(C) Statement of Additional Facts in Opposition to Facebook, Inc.'s Motion for Summary Judgment (Van Baren, Bruce)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
Plaintiff,
v.
FACEBOOK, INC.
Defendant.

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Civil Action No.: 11 CV 6867
HONORABLE JOHN W. DARRAH
Jury Trial Demanded

TIMELINES, INC.’s MOTION FOR LEAVE TO FILE ADDITIONAL FACTS
IN ITS LOCAL RULE 56.1(b)(3)(C) STATEMENT OF ADDITIONAL FACTS IN
OPPOSITION TO FACEBOOK, INC.’S MOTION FOR SUMMARY JUDGMENT
Plaintiff Timelines, Inc., through its attorneys, Reed Smith LLP, moves this Court for
leave to file additional facts to its Local Rule 56.1(b)(3)(C) Statement of Additional Facts in
opposition to Defendant Facebook, Inc.’s Motion for Summary Judgment for the reasons set
forth in its accompanying Memorandum of Law.
Dated: February 22, 2013

Respectfully submitted,
TIMELINES, INC.,
Plaintiff/Counter-Defendant

By: /s/ Douglas A. Albritton______
James T. Hultquist (SBN 6204320)
Douglas A. Albritton (SBN 6228734)
Michael L. DeMarino (SBN 6298337)
Bruce R. Van Baren (SBN 6310375)
REED SMITH LLP
10 South Wacker Drive
Chicago, IL 60606-7507
312-207-1000
Counsel for TIMELINES, INC.

CERTIFICATE OF SERVICE
I, the undersigned attorney, certify that I electronically filed TIMELINES, INC.’S
MOTION FOR LEAVE TO FILE ADDITIONAL FACTS IN ITS LOCAL RULE
56.1(b)(3)(C) STATEMENT OF ADDITIONAL FACTS IN OPPOSITION TO
FACEBOOK, INC.’S MOTION FOR SUMMARY JUDGMENT. Pursuant to Rule 5(b)(3)
of the Federal Rules of Civil Procedure and Local Rule 5.9, I have thereby electronically served
all Filing Users.
February 22, 2013

Respectfully submitted,
TIMELINES, INC.,
Plaintiff/Counter-Defendant

By: /s/ Douglas A. Albritton
James T. Hultquist (SBN 6204320)
Douglas A. Albritton (SBN 6228734)
Michael L. DeMarino (SBN 6298337)
Bruce R. Van Baren (SBN 6310375)
REED SMITH LLP
10 South Wacker Drive
Chicago, IL 60606-7507
Telephone: [phone]
Facsimile: [phone]
Counsel for TIMELINES, INC.
US_ACTIVE-112073848

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