Datatreasury Corporation v. Wells Fargo & Company et al

Filing 576

MOTION for Leave to File Excess Pages (UnionBanCal's Reply to Plaintiff's Amended Response to Motion to Dismiss Plaintiff's Complaint Pursuant to Fed. R. Civ. P. 12(b)(2) (Unopposed) by Unionbancal Corporation. (Attachments: #1 Exhibit 1 - Defendant's Reply to Plaintiff's Amended Response#2 Affidavit Affidavit of Gerardy Carrenard (to Defendant's Reply to Plaintiff's Amended Response)#3 Exhibit A (to Defendant's Reply to Plaintiff's Amended Response)#4 Exhibit B (to Defendant's Reply to Plaintiff's Amended Response)#5 Exhibit C (to Defendant's Reply to Plaintiff's Amended Response)#6 Text of Proposed Order)(Ainsworth, Jennifer)

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Datatreasury Corporation v. Wells Fargo & Company et al Doc. 576 Case 2:06-cv-00072-DF-CMC Document 576 Filed 03/01/2007 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION DATATREASURY CORPORATION, Plaintiff, v. WELLS FARGO & COMPANY, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 2-06CV-72 UNOPPOSED MOTION TO EXCEED PAGE LIMITATION Defendant UnionBanCal Corporation ("UnionBanCal") files this unopposed motion to exceed page limitations in its Reply to Plaintiff's Amended Response to Motion to Dismiss Plaintiff's Complaint Pursuant to Fed. R. Civ. P. 12(b)(2). 1. Defendant seeks leave to exceed the ten page limit for replies to dispositive motions in order to attach exhibits to its Reply to Plaintiff's Amended Response to Defendant's Motion to Dismiss Plaintiff's Complaint Pursuant to Fed. R. Civ. P. 12(b)(2). The Plaintiff's response was 23 pages excluding exhibits (298 pages including exhibits). In order to adequately respond to the motion, UnionBanCal seeks leave to file a reply within the 10-page limit, but needs to attach exhibits to respond to specific issues raised by Plaintiff. Defendant's Reply to Plaintiff's Amended Response. 2. Based on the foregoing, UnionBanCal Corporation respectfully requests that the See Exhibit 1, Court grant this unopposed motion. Dockets.Justia.com Case 2:06-cv-00072-DF-CMC Document 576 Filed 03/01/2007 Page 2 of 3 Respectfully submitted, March 1, 2007 /s/ Jennifer Parker Ainsworth________________________ Jennifer Parker Ainsworth Texas Bar No. 00784720 WILSON, SHEEHY, KNOWLES, ROBERTSON & CORNELIUS, P.C. 909 ESE Loop 323 Suite 400 Tyler, Texas 75701 T: (903) 509-5000 F: (903) 509-5092 jainsworth@wilsonlawfirm.com Richard Hogan Texas Bar No. 09802010 PILLSBURY WINTHROP SHAW PITTMAN LLP 2 Houston Center 909 Fannin Street 22nd Floor Houston TX 77010 T: (713) 425-7327 F: (713) 425-7373 richard.hogan@pillsburylaw.com Raymond L. Sweigart (pro hac vice submitted) Scott J. Pivnick (pro hac vice submitted) PILLSBURY WINTHROP SHAW PITTMAN LLP 1650 Tysons Blvd. McLean, VA 22102-4859 T: (703) 770-7900 F: (703) 905-2500 raymond.sweigart@pillsburylaw.com scott.pivnick@pillsburylaw.com Attorneys for Defendant, UnionBanCal Corporation 2 Case 2:06-cv-00072-DF-CMC Document 576 Filed 03/01/2007 Page 3 of 3 CERTIFICATE OF CONFERENCE Counsel for Defendant UnionBanCal hereby certifies that she contacted counsel for the Plaintiff, and Plaintiff does not oppose this motion. /s/ Jennifer Parker Ainsworth Jennifer Parker Ainsworth CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on March 1, 2007. Any other counsel of record will be served by facsimile transmission and first class mail. /s/ Jennifer Parker Ainsworth Jennifer Parker Ainsworth 3

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