Vargas et al v. Pfizer Inc. et al

Filing 105

FIRST MOTION for Reconsideration of Court's bench order on November 3, 2006. Document filed by Ralph Vargas. (Chin, Paul)

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ZOR5 5 #$rg C $!0. -'2r *rg1( ) TT 9 &*(Z*(! 7...Z T)70 ( 68T -2D 0 OUT0 B. requiring Defendant Transeau to immediately reimburse Plaintiffs for all costs, expenses and expert fees Plaintiffs incur as a result of having to engage their experts to analyze and respond to Defendant Transeau' additional expert evidence of s striking similarity and independent creation; and C. granting any other or further relief to the Plaintiffs as the Court deems just and appropriate. The date for Defendant Transeau' answering memorandum, if any, shall be due s on a date consistent with time required for any such answering memoranda as specified in Rule 6.1(b) of the Local Rules of Local Rules of the United States District Courts for the Southern and Eastern Districts of New York. WHEREFORE, Plaintiffs respectfully request that the Court grant their motion for reconsideration and provide the relief identified in one of the two proposed orders attached to Plaintiffs' memorandum of law attached hereto. Dated: New York, New York November 9, 2006 Respectfully submitted, s/ Paul A. Chin Paul A. Chin, Esq. (PC 9656) LAW OFFICES OF PAUL A. CHIN The Woolworth Building 233 Broadway, 5th Floor New York, NY 10279 (212) 964-8030 Attorneys for Plaintiffs To: Julie Ahrens, Esq. Kirkland & Ellis, LLP 555 California Street, Suite 2700 San Francisco, CA 94104 Counsel for Defendant Transeau David S. Olson, Esq. Anthony Falzone, Esq. Center for Internet and Society 2 Stanford Law School 559 Nathan Abbott Way Stanford, CA 94305-8610 Counsel for Defendant Transeau Eric M. Stahl, Esq. Davis Wright Tremaine, LLP 1501 4th Avenue, Suite 2600 Seattle, WA 98101-1688 Counsel for Defendant East West Communications 3 CERTIFICATE OF SERVICE On the 9th day of November, 2006, a true and correct copy of PLAINTIFFS' NOTICE OF MOTION FOR RECONSIDERATION, and the attached Memorandum of Law, was served pursuant to Rule 5.2 of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, and via e-mail and first-class mail, postage pre-paid, and placed in an official depository under the exclusive care and custody of the United States Postal Service within the State of New York, to the following the attorneys representing the Defendants: Julie Ahrens, Esq. Kirkland & Ellis, LLP 555 California Street, Suite 2700 San Francisco, CA 94104 Counsel for Defendant Transeau David S. Olson, Esq. Anthony Falzone, Esq. Center for Internet and Society Stanford Law School 559 Nathan Abbott Way Stanford, CA 94305-8610 Counsel for Defendant Transeau Eric M. Stahl, Esq. Davis Wright Tremaine, LLP 1501 4th Avenue, Suite 2600 Seattle, WA 98101-1688 Counsel for Defendant East West Communications 11/9/06 Date s/ Paul A. Chin Paul A. Chin, Esq. (PC 9656) LAW OFFICES OF PAUL A. CHIN The Woolworth Building 233 Broadway, 5th Floor New York, NY 10279 (212) 964-8030 Attorneys for Plaintiffs 4

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