TimesLines, Inc v. Facebook, Inc.

Filing 76

MOTION by Plaintiff TimesLines, Inc, Counter Defendant TimesLines, Inc[Plaintiff Timelines, Inc.'s Motion For Narrow Relief From The Protective Order] (Albritton, Douglas)

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
Jury Trial Demanded

PLAINTIFF TIMELINES, INC.’S MOTION FOR
NARROW RELIEF FROM THE PROTECTIVE ORDER
Plaintiff/Counter-Defendant Timelines, Inc. (“Timelines”), for the reasons set forth in its
accompanying memorandum of law, seeks narrow relief from the Court’s April 24, 2012
Protective Order. In particular, Timelines is seeking relief to permit its President and corporate
representative, Brian Hand, to view a few revenue documents Facebook has designated as
Highly Confidential – Outside Counsel Only. These documents, as yet unknown to Mr. Hand,
form part of the claim for relief Timelines seeks in this case. Without knowledge of these
documents, Mr. Hand cannot meaningfully participate in the trial or in pre-trial discussions
(including any settlement questions the Court may direct to Timelines).
WHEREFORE, for the reasons stated herein and as set forth more fully in the
accompanying Memorandum of Law, Timelines respectfully moves for the following narrow
relief from the Protective Order:
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that Brian Hand, President of Timelines, be permitted to review Facebook
documents FB-TL 0011912 – 11919;

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that Mr. Hand be permitted to review the entirety of Plaintiff’s and Defendant’s
expert damage reports (an opening and response-to-rebuttal report from
Timelines, its expert David Haas, and a rebuttal report from Facebook, its expert
being Christopher J. Bokhart); and

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such further relief as is just and appropriate depending on the issues as briefed and
argued.

Dated: January 30, 2013
Respectfully submitted,
TIMELINES, INC.
By:

/s/ Douglas A. Albritton
One of its Attorneys
James T. Hultquist (#6204320)
Douglas Alan Albritton (#6228734)
Raven Moore (#6280665)
REED SMITH LLP
10 South Wacker Drive, 40th Floor
Chicago, Illinois 60606-7507
[phone]
[phone] (facsimile)
[e-mail]
[e-mail]
[e-mail]

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