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)

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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: (646) 351-0006 Facsimile: (212) 208-6874 BRAGAR EAGEL & SQUIRE, P.C. by: /s/ Raymond A. Bragar Raymond A. Bragar 885 Third Ave., Suite 3040 New York, New York 10022 Telephone: (212) 308-5858 Facsimile: (212) 208-2519 Attorneys for Plaintiff 2

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