White et al v. West Publishing Corporation et al

Filing 66

COUNTER STATEMENT TO 51 Rule 56.1 Statement. Document filed by Edward L. White, P.C.. (Blue, Gregory)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
EDWARD L. WHITE, P.C.,

12-CV-1340 (JSR)
ECF CASE

Plaintiff,
- against WEST PUBLISHING CORPORATION d/b/a “West”;
and REED ELSEVIER INC.,
d/b/a LexisNexis,
Defendants.

PLAINTIFF’S RESPONSE TO DEFENDANT WEST PUBLISHING
CORPORATION’S RULE 56.1 STATEMENT
Pursuant to Rule 56 of the Federal Rules of Civil Procedure and Rule 56.1 of the
Local Civil Rules of the United States District Court for the Southern District of New
York, Plaintiff Edward L. White, P.C.(“Plaintiff”), by its undersigned attorneys,
respectfully submits the following response as to defendant West Publishing
Corporation’s (“West”) Rule 56.1 Statement.
8:

Plaintiff has no dispute with the mechanical steps West takes with each

document that it uploads onto its system. Plaintiff objects to the characterization of those
steps as “enhancements”. Plaintiff contends that all the mechanical steps taken by West
only promote West’s goal of making the documents accessible to subscribers.
13.

Plaintiff has no dispute with the mechanical steps West takes with each

document that it uploads onto its system. Plaintiff objects to the characterization of those
steps as having “enhanced” any document. Plaintiff contends that all the mechanical steps

taken by West only promote West’s goal of making the documents accessible to
subscribers.
Dated: New York, New York
October 23, 2012
Gregory A. Blue
GREGORY A. BLUE, P.C.
The Chrysler Building
405 Lexington Avenue, Suite 2600
New York, NY 10174
Telephone: [phone]
Facsimile: [phone]
BRAGAR EAGEL & SQUIRE, P.C.
by: /s/ Raymond A. Bragar
Raymond A. Bragar
885 Third Ave., Suite 3040
New York, New York 10022
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff

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