Datatreasury Corporation v. Wells Fargo & Company et al

Filing 649

MOTION for Leave to File Excess Pages by Unionbancal Corporation. (Attachments: #1 Exhibit UnionBanCal's Motion for Clarification#2 Affidavit Affidavit of Gerardy Carrenard in Support of UnionBanCal's Motion for Clarification#3 Exhibit Exhibit 1 to UnionBanCal's Motion for Clarification#4 Exhibit Exhibit 2 to UnionBanCal's Motion for Clarification#5 Exhibit Exhibit 3 to UnionBanCal's Motion for Clarification#6 Exhibit Exhibit 4 to UnionBanCal's Motion for Clarification#7 Text of Proposed Order for Motion to Exceed Page Limits#8 Text of Proposed Order Proposed Order for Motion for Clarification)(Pivnick, Scott) Certificate of Conference added on 4/16/2007 (mpv, ). Modified on 4/16/2007 (mpv, ).

Datatreasury Corporation v. Wells Fargo & Company et al

Doc. 649

Case 2:06-cv-00072-DF-CMC

Document 649

Filed 04/13/2007

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

UNIONBANCAL CORPORATION'S MOTION TO EXCEED PAGE LIMITATION Defendant UnionBanCal Corporation ("UnionBanCal") files this motion to exceed page limitations in Defendant UnionBanCal Corporation's Motion for Clarification or for a Protective Order Regarding Discovery Order and Enlargement of Time 1. UnionBanCal seeks leave to exceed the fifteen page limit for non-dispositive

motions in order to fully explain the basis of its Motion for Clarification and to provide a sufficient description of the documents and information at issue in UnionBanCal's Motion so that the Court can make a fully informed decision. UnionBanCal's Motion needs to include additional pages in its Motion in order to describe the contents of the documents subject to the Motion and the burdens that would be imposed if UnionBanCal were forced to review and produce the documents at issue. In order to adequately describe these issues, UnionBanCal seeks leave to file a 19 Motion. See Exhibit 1, Defendant UnionBanCal Corporation's Motion for Clarification or for a Protective Order Regarding Discovery Order (D.E. No. 597) and Enlargement of Time.

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Dockets.Justia.com

Case 2:06-cv-00072-DF-CMC

Document 649

Filed 04/13/2007

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2.

Counsel for UnionBanCal was unable to confer with counsel for plaintiff to

determine if plaintiff opposes this Motion but will update the Court once counsel for UnionBanCal is able to discuss the issue with plaintiff's counsel. 3. this motion. Respectfully submitted, April 13, 2007 /s/ Scott J. Pivnick Raymond L. Sweigart (pro hac vice) Scott J. Pivnick (pro hac vice) PILLSBURY WINTHROP SHAW PITTMAN LLP 1650 Tysons Blvd. McLean, VA 22102-4859 T: [phone] F: [phone] [e-mail] [e-mail] Jennifer Parker Ainsworth Texas Bar No. 00784720 WILSON, SHEEHY, KNOWLES, ROBERTSON & CORNELIUS, P.C. 909 ESE Loop 323 Suite 400 Tyler, Texas 75701 T: [phone] F: [phone] [e-mail] Richard Hogan Texas Bar No. 09802010 PILLSBURY WINTHROP SHAW PITTMAN LLP 2 Houston Center 909 Fannin Street 22nd Floor Houston TX 77010 T: [phone] F: [phone] [e-mail] Attorneys for Defendant, UnionBanCal Corporation
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Based upon the foregoing, UnionBanCal respectfully requests that the Court grant

Case 2:06-cv-00072-DF-CMC

Document 649

Filed 04/13/2007

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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 this the 13th day of April, 2007. /s/ Scott J. Pivnick

CERTIFICATE OF CONFERENCE Counsel for Defendant UnionBanCal hereby certifies that he was not able to confer with counsel for the Plaintiff to determine if Plaintiff opposes this motion. Counsel for UnionBanCal will inform the Court when he is able to contact counsel for Plaintiff and determines Plaintiff's position on the motion. /s/ Scott J. Pivnick

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