SANDLER v. CALCAGNI et al

Filing 120

SANDLER v. CALCAGNI et al

Doc. 120

UNITED STATES DISTRICT COURT DISTRICT OF MAINE
SHANA SANDLER, Plaintiff v. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 1:07-cv-00029

MIA CALCAGNI et al, Defendants

PLAINTIFF'S MOTION TO EXCEED PAGE LIMITS IN RESPONDING TO DEFENDANT BOOKSURGE'S MOTION FOR SUMMARY JUDGMENT ON ALL CLAIMS OF PLAINTIFF

Pursuant to Local Rule 7(e), Plaintiff Shana Sandler hereby moves for leave to file a Memorandum of Law in Opposition to Defendant Booksurge's Motion for Summary Judgment on All Claims of Plaintiff Shana Sandler in excess of twenty (20) pages in length. The grounds for this Motion are set forth in the incorporated Memorandum of Law. MEMORANDUM OF LAW Defendant Booksurge has filed a Motion for Summary Judgment which consists of 34 pages, together with a Statement of Material Facts consisting of 159 statements. Booksurge has moved for summary judgment on multiple alternative grounds on the six causes of action asserted by Plaintiff. In order to adequately address each issue raised in Defendants' Motion for Summary Judgment, together with the interrelated defenses asserted by Booksurge, Plaintiff will be required to exceed the twenty (20) page limit for dispositive motions set forth in Local Rule

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7(e). Plaintiff's estimate of the length of its Memorandum is not expected to exceed forty (40) pages. WHEREFORE, Plaintiff respectfully requests leave of Court pursuant to Rule 7(e) to file a Memorandum of Law that exceeds the twenty (20) page limit for dispositive motions. Dated at Bangor, Maine, this 7th day of April, 2008. PLAINTIFF, Shana Sandler,

By:___/s/ Bernard J. Kubetz Bernard J. Kubetz, Esq. Eaton Peabody P. O. Box 1210 80 Exchange Street Bangor, Maine 04402-1210 [phone] [e-mail] CERTIFICATE OF SERVICE I, Bernard J. Kubetz, hereby certify that on April 7, 2008 I electronically filed the foregoing Plaintiff's Motion to Exceed Page Limits in Responding to Defendant Booksurge's Motion for Summary Judgment on All Claims of Plaintiff with the Clerk of the United States District Court using the CM/ECF system, which will send notification of such filing to the following: Bruce Mallonee, Esq. Rudman & Winchell, LLC P. O. Box 1401 Bangor, Maine 04402-1401 [e-mail] Steven P. Wright, Esq. Kirkpatrick & Lockhart Preston Gates Ellis LLP One Lincoln Street Boston, Massachusetts 02111-2950 [e-mail]

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Matthew J. Segal, Esq. Stephen A. Smith, Esq. Kirkpatrick & Lockhart Preston Gates Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104-1158 [e-mail] J. William Druary, Jr., Esq. Marden, Dubord, Bernier & Stevens P. O. Box 708 Waterville, Maine 04903-0708 [e-mail] Harold J. Friedman, Esq. Friedman, Gaythwaite Wolf & Leavitt P. O. Box 4726 Portland, Maine 04112-4726 [e-mail]

/s/ Bernard J. Kubetz_______ Bernard J. Kubetz

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