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)

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION TIMELINES, INC. Plaintiff, v. FACEBOOK, INC. Defendant. ) ) ) ) ) ) ) ) ) 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: +1 312 207 1000 Facsimile: +1 312 207 6400 Counsel for TIMELINES, INC. US_ACTIVE-112073848 2

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