Filing 21

RESPONSE to Motion re 12 MOTION to Dismiss Amended Complaint and MOTION for Leave to File Second Amended Complaint filed by QVC, INC..Memorandum, Certificate of Service. (Attachments: # 1 Memorandum of Law# 2 Exhibit A# 3 Certificate of Service# 4 Text of Proposed Order Proposed Order)(METZ, NATHANIEL) Modified on 3/16/2007 (np).

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QVC, INC. v. SCHIEFFELIN et al Doc. 21 Case 2:06-cv-04231-TON Document 21 Filed 03/15/2007 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ____________________________________ : QVC, INC. : CIVIL ACTION : Plaintiff, : : v. : NO. 06-cv-4231(TON) : STACEY SCHIEFFELIN, : DAVID SCHIEFFELIN, : and MODELS PREFER, LTD., : : Defendants. : ____________________________________: MOTION OF PLAINTIFF QVC, INC. FOR LEAVE TO FILE SECOND AMENDED COMPLAINT Plaintiff, QVC, Inc., by and through its undersigned counsel, respectfully moves this Court for Order granting Plaintiff leave to file a Second Amended Complaint for the reasons set forth in the accompanying memorandum of law which is incorporated herein by reference. SAUL EWING LLP /s/ Nathaniel Metz By:__________________________ Nathaniel Metz, Esquire (215) 972-8385 (215) 972-2282 (Telefacsimile) Centre Square West 1500 Market Street, 38th Floor Philadelphia, PA 19102-2186 Attorneys for Plaintiff, QVC, Inc.

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