In Re: Apple iPhone 3G and 3GS MMS Marketing and Sales Practices Litigation

Filing 265

EXPARTE/CONSENT MOTION for Leave to File Excess Pages by Apple Inc. by Defendant. (Attachments: # 1 Proposed Order)(Reference: All Actions)(Urquhart, Quentin)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: APPLE iPHONE 3G AND 3GS
“MMS” MARKETING AND SALES
PRACTICES LITIGATION

CIVIL ACTION

THIS DOCUMENT RELATES TO:

SECTION “J”
JUDGE BARBIER

MDL No. 2116

All Actions
MAGISTRATE JUDGE WILKINSON
DEFENDANT APPLE INC.’S MOTION FOR
LEAVE TO FILE REPLY MEMORANDUM IN EXCESS OF TEN PAGES
NOW INTO COURT, through undersigned counsel, comes Defendant, Apple Inc.
(“Apple”), who respectfully requests that this Court grant it leave to file a Reply
Memorandum in excess of ten (10) pages to Plaintiffs’ Opposition to the Motion to Compel
Arbitration.

Plaintiffs’ Opposition was approximately forty (40) pages in length and

addresses complex issues regarding the recent decision by the United States Supreme Court
in AT&T Mobility LLC v. Concepcion, 131 S. Ct. 1740 (2011). Accordingly, Apple requires
five (5) additional pages to appropriately respond to the arguments and issues raised in the
opposition. Apple believes the Reply Memorandum will be helpful to the Court in
evaluating the Motion to Compel Arbitration.
WHEREFORE, Defendant, Apple Inc., requests that this Court grant it leave to file a
Reply Memorandum of fifteen (15) pages to Plaintiffs’ Opposition to the Motion to Compel
Arbitration.

Respectfully submitted,
__/s/ Quentin F. Urquhart___________
IRWIN FRITCHIE URQUHART & MOORE, LLC
QUENTIN F. URQUHART, JR. (#14475)
DAVID W. O’QUINN (#18366)
DOUGLAS J. MOORE (#27706)
400 Poydras Street, Suite 2700
New Orleans, Louisiana 70130
Telephone: [phone]
Facsimile: [phone]
PENELOPE A. PREOVOLOS (admitted pro hac vice)
STUART C. PLUNKETT (?)
MORRISON & FOERSTER, LLP
425 Market Street
San Francisco, CA 94105-2482
Telephone: [phone]
Facsimile: [phone]
Counsel for Apple Inc.

CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing pleading has been electronically filed on
December 8, 2011, with the Clerk of Court by using the CM/ECF system which will send a
notice of electronic filing.
__/s/ Quentin F. Urquhart_