TimesLines, Inc v. Facebook, Inc.

Filing 117

MOTION by Plaintiff TimesLines, Inc, Counter Defendant TimesLines, Inc to amend/correct order on motion in limine,,, ruling on motion hearing,,, set deadlines/hearings,, 113 the Schedule entered by the court on March 13, 2013, MOTION by Plaintiff TimesLines, Inc, Counter Defendant TimesLines, Inc for extension of time for filing Motions in Limine and Responses thereto (Van Baren, Bruce)

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

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

AGREED MOTION TO AMEND THE SCHEDULE ENTERED BY THE COURT
ON MARCH 13, 2013 AND TO EXTEND THE DEADLINES FOR
FILING MOTIONS IN LIMINE AND RESPONSES THERETO
Plaintiff/Counter-Defendant Timelines, Inc. (“Timelines”) and Defendant/CounterPlaintiff Facebook, Inc. (“Facebook”), being in agreement, hereby respectfully move the Court to
amend the schedule set forth in the Minute Order (Docket Entry # 113) and to extend the
deadlines for filing motions in limine and responses thereto. In support of this Agreed Motion,
the parties state as follows:
1.

While both parties are busy preparing for trial, attorneys for Timelines have had

trials and disputes in other matters that just resolved in the prior few days. Additionally, counsel
for both parties have been discussing stipulations in an effort to narrow the number of motions in
limine to be filed with the Court.
2.

Although the Court’s standing pre-trial order did not set a due date for the filings

of motions in limine, the parties had proposed a schedule whereby motions in limine would be
filed today, April 5, 2013, with responses due on April 12, 2013.
3.

Due to the aforementioned scheduling conflicts, the parties are, by this motion,

seeking to amend the schedule entered by the Court on March 13, 2013, by one day, as follows:

the deadline for filing motions in limine is extended from April 5, 2013, until April 8, 2013; the
deadline for filing answers to any motions in limine is extended from April 12, 2013 until April
15, 2013.
4.

This request is made in good faith and not for the purpose of delay and neither

party will suffer harm or prejudice upon the granting of this Motion.
WHEREFORE, Plaintiff/Counter-Defendant Timelines, Inc. and Defendant/CounterPlaintiff Facebook, Inc. respectfully request that this Court enter an order extending the
deadlines to file motions in limine and responses thereto; and for such other and further relief as
this Court deems as just and proper.

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TIMELINES, INC.

By:

/s/ Bruce R. Van Baren
One of its Attorneys
James T. Hultquist (#6204320)
Douglas A. Albritton (#6228734)
Michael L. DeMarino (#6298337)
Bruce R. Van Baren (#6310375)
REED SMITH LLP
10 South Wacker Drive, 40th Floor
Chicago, Illinois 60606-7507
[phone]
[phone] (facsimile)
[e-mail]
[e-mail]
[e-mail]
[e-mail]

FACEBOOK, INC.
By:

One of its Attorneys

/s/ Thomas M. Monagan, III
Steven D. McCormick (#1824260)
Thomas M. Monagan, III (#6278060)
KIRKLAND & ELLIS LLP
300 North Lasalle
Chicago, IL 60654-3406
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

/s/ Peter J. Willsey
Michael G. Rhodes (Admitted Pro Hac Vice)
Peter J. Willsey (Admitted Pro Hac Vice)
Anne H. Peck (Admitted Pro Hac Vice)
Jeffrey T. Norberg (Admitted Pro Hac Vice)
Gavin L. Charlston (Admitted Pro Hac Vice)
COOLEY LLP
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Phone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that he served the foregoing Agreed
Motion for Extension to Amend the Schedule Entered by the Court on March 13, 2013 and to
Extend the Deadlines for Filing Motions in Limine and Responses Thereto by means of the
Court’s CM/ECF System, which causes a true and correct copy of the same to be served
electronically on all CM/ECF registered counsel of record, on April 5, 2013.

/s/ Bruce R. Van Baren___________
Bruce R. Van Baren

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