CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al

Filing 117

MOTION for Leave to File Reply Brief in Further Support of Renewed Motion to Compel Production of Documents filed by FACEBOOK, INC., THEFACEBOOK, LLC.Certificate of Service. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit Reply Brief)(MCCOOE, DENNIS)

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CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al Doc. 117 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA CROSS ATLANTIC CAPITAL PARTNERS, INC. Plaintiff, v. FACEBOOK, INC and THEFACEBOOK, LLC, Defendants. : : : : CIVIL ACTION : : NO. 07-CV-02768-JP : : JURY TRIAL DEMANDED : : : MOTION FOR LEAVE TO FILE REPLY BRIEF IN FURTHER SUPPORT OF RENEWED MOTION TO COMPEL PRODUCTION OF DOCUMENTS Defendants Facebook, Inc. and TheFacebook (collectively "Facebook"), by their undersigned counsel, respectfully move for leave to file a Reply Brief in Further Support of Renewed Motion to Compel Production of Documents (attached hereto as Exhibit "A" for the Court's consideration). Because Plaintiff's Response in Opposition to Defendants' Renewed Motion to Compel Production of Documents raised certain new factual issues and legal theories, Facebook's Reply Brief is needed to concisely address these newly raised arguments and thereby provide the Court with a comprehensive briefing on all issues before the Court on the Renewed Motion to Compel Production of Documents. 900200.00001/11790373v.1 Dockets.Justia.com WHEREFORE, Defendants respectfully request that this Honorable Court grant their Motion for Leave to File Reply Brief in Further Support of Renewed Motion to Compel Production of Documents. Dated: June 13, 2008 By: /s/ Dennis P. McCooe Heidi L. Keefe Mark R. Weinstein Craig W. Clark WHITE & CASE LLP 3000 El Camino Real 5 Palo Alto Square, 9th Floor Palo Alto, CA 94306 Alfred W. Zaher Dennis P. McCooe BLANK ROME LLP One Logan Square Philadelphia, PA 19103 Attorneys for FACEBOOK, INC. and THEFACEBOOK, LLC 2 900200.00001/11790373v.1 CERTIFICATE OF SERVICE This is to hereby certify that on this 13th day of June, 2008, I caused a true and correct copy of the foregoing documents to be served via this Court's Electronic Filing ("ECF") System, upon the following: Frederick A. Tecce, Esq. McShea/Tecce, P.C. The Bell Atlantic Tower 28th Floor 1717 Arch Street Philadelphia, PA 19103 ftecce@mcshea-tecce.com Thomas J. Duffy, Esq. Patrick J. Keenan, Esq. Duffy & Keenan One Liberty Place, 55th Floor 1650 Market Street Philadelphia, PA 19103 pjk@duffykeenan.com Counsel for Plaintiff Cross Atlantic Capital Partners, Inc. /s/ Dennis P. McCooe Dennis P. McCooe 3 900200.00001/11790373v.1

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