TimesLines, Inc v. Facebook, Inc.

Filing 72

NOTICE of Motion by Brendan J. Hughes for presentment of motion in limine 69 before Honorable John W. Darrah on 1/8/2013 at 09:30 AM. (Hughes, Brendan)

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

NOTICE OF MOTION
TO:

All Counsel of Record as reflected in the Court’s CM/ECF system for this case.
PLEASE TAKE NOTICE that on January 8, 2013 at 9:30 a.m., or as soon thereafter as

counsel may be heard, the Parties will appear before the Honorable Judge John W. Darrah, or
any judge sitting in his stead, in Courtroom 1203 of the United States District Court, 219 South
Dearborn, Chicago, Illinois, and shall then and there present the filed Motion to Exclude Dr. Eli
Seggev’s Survey and Related Expert Report and Testimony.
In addition, at the presentment hearing, Defendant Facebook, Inc. respectfully requests
that the Court clarify that the parties’ deadline to file dispositive motions in this matter is January
31, 2013. The parties included that deadline in their Joint Initial Status Report. Further, during
the January 24, 2012 hearing, it appeared that the Court had agreed to set January 31, 2013 as the
deadline for filing dispositive motions. To date, however, the Court has not issued an order
setting the deadline.

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Dated: December 20, 2012

Respectfully submitted,

COOLEY LLP
By:

/s/ Brendan J. Hughes
Peter J. Willsey (pro hac vice)
Brendan Hughes (pro hac vice)
COOLEY LLP
777 6th Street, NW, Suite 1100
Washington, DC 20001
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Michael G. Rhodes (pro hac vice)
COOLEY LLP
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Steven D. McCormick (#1824260)
KIRKLAND & ELLIS LLP
300 North LaSalle
Chicago, IL 60654-3406
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Counsel for Facebook, Inc.

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CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that he served the foregoing NOTICE OF
MOTION 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 December
20, 2012.
Dated: December 20, 2012
/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
777 6th Street, NW, Suite 1100
Washington, DC 20001
Tel: [phone]
Fax: [phone]
Email: [e-mail]

180727 DC

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