Connectu, Inc. v. Facebook, Inc. et al

Filing 265

MOTION for Extension of Time to 02/19/2009 to oppose ConnectU Inc.'s Motion to Disqualify Counsel by Connectu, Inc., Cameron Winklevoss, Tyler Winklevoss, Divya Narendra. (Attachments: #1 Text of Proposed Order)(Hornick, John) Modified to remove duplicate text on 1/28/2009 (Seelye, Terri).

Connectu, Inc. v. Facebook, Inc. et al

Doc. 265

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS ) ) ) ) ) Plaintiffs, ) ) v. ) FACEBOOK, INC., MARK ZUCKERBERG, ) ) EDUARDO SAVERIN, DUSTIN ) MOSKOVITZ, ANDREW MCCOLLUM, ) AND THEFACEBOOK LLC, ) ) Defendants. ) CONNECTU, INC., CAMERON WINKLEVOSS, TYLER WINKLEVOSS, AND DIVYA NARENDRA,

CIVIL ACTION NO. 1:07-CV-10593 (DPW) Related Action No. 1:04-cv-11923 (DPW) JURY TRIAL DEMANDED

UNOPPOSED MOTION FOR EXTENSION OF TIME Plaintiffs Cameron and Tyler Winklevoss and Divya Narendra ("Plaintiffs") respectfully request that this Court grant an extension of time for Plaintiffs to oppose ConnectU, Inc.'s Motion to Disqualify the three law firms currently representing Plaintiffs (namely, Finnegan, Henderson, Farabow, Garrett & Dunner, LLP; Boies, Schiller & Flexner, LLP; and Griesinger, Tighe & Maffei LLP) filed by Hoge, Fenton, Jones & Appel, Inc. on behalf of ConnectU, Inc. on January 22, 2009 (Dkt. 262), and for ConnectU, Inc. to reply to Plaintiffs' opposition. Plaintiffs' opposition is currently due February 5, 2009. This motion requests an extension of time to February 19, 2009 for Plaintiffs to oppose ConnectU, Inc.'s Motion to Disqualify Counsel and an extension of time to February 26, 2009 for ConnectU, Inc. to reply to Plaintiffs' opposition. On January 26, 2009, James Towery of the Hoge, Fenton law firm consented to the extension of time sought herein for Plaintiffs' opposition. Specifically, Mr. Towery stated that "On behalf of ConnectU, I do not object to the two week extension you are seeking both in the

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9th Circuit motion and the Massachusetts action." Thus, Plaintiffs expect this motion will be unopposed The parties have a standing agreement consenting to reply briefs, and therefore Plaintiffs consent to the extension of time sought by this motion for ConnectU, Inc.'s reply to Plaintiffs' opposition. For the convenience of the Court, a proposed Order was filed contemporaneously with this motion. Respectfully submitted, DATED: January 27, 2009 By: /s/ John F. Hornick John F. Hornick (pro hac vice) Margaret A. Esquenet (pro hac vice) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. 901 New York Avenue N.W. Washington, DC 20001 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Michael Underhill (pro hac vice) Evan A. Parke (pro hac vice) BOIES, SCHILLER & FLEXNER LLP 5301 Wisconsin Avenue, NW Washington, DC 20015 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Daniel P. Tighe (BBO# 556583) Scott McConchie (BBO# 634127) GREISINGER, TIGHE, and MAFFEI, LLP. 176 Federal St. Boston, MA 02110 Telephone: [phone] Facsimile: [phone] [e-mail]

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[e-mail] Attorneys for Cameron Winklevoss, Tyler Winklevoss, and Divya Narendra

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CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified in the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non-registered participants on January 27, 2009. /s/ John F. Hornick John F. Hornick