Northeastern University et al v. Google, Inc.,

Filing 156

Unopposed MOTION for Leave to File Damages Motions in Limine Exceeding Page Limit by Google, Inc.,. (Attachments: # 1 Text of Proposed Order Proposed Order)(Scarpati, Jennifer)

Northeastern University et al v. Google, Inc.,

Doc. 156

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

NORTHEASTERN UNIVERSITY and JARG CORPORATION Plaintiffs, v. GOOGLE INC. Defendant. DEFENDANT GOOGLE INC.'S UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMIT Defendant Google Inc. ("Google") files this Unopposed Motion for Leave to Exceed Page Limit concerning Defendant Google Inc.'s Damages Motions in Limine, Dkt. No. 154, and respectfully shows as follows: Google seeks leave to file its Damages Motions in Limine, which are 21 pages in length when combined, excluding exhibits. The combined Motions exceed the page limit set forth in Local Rule CV-7(a)(2) by 6 pages, excluding exhibits. The additional pages are necessary because of the sheer number of issues presented within these ten Motions, the complexity of those issues, and the severity of the relief sought, including, inter alia, preclusion of several different aspects of testimony to be provided by John C. Jarosz, Plaintiffs' damages expert. Google's counsel has conferred with counsel for Plaintiffs, and said counsel is not opposed to this motion. Civil Action No. 2:07-CV-486-CE Jury Trial Demand

Dockets.Justia.com

Dated: March 8, 2011

Respectfully submitted, FISH & RICHARDSON P.C. By: /s/ Jennifer N. Scarpati Jennifer Parker Ainsworth (SBN 00784720) [e-mail] Wilson, Robertson & Cornelius, P.C. One American Center 909 ESE Loop 323, Suite 400 Tyler, TX 75701 Telephone: [phone] Facsimile: [phone] Ruffin B. Cordell (SBN 04820550) [e-mail] FISH & RICHARDSON P.C. 1425 K Street, N.W., 11th Floor Washington, DC 20005-3500 Telephone: [phone] Facsimile: [phone] Jason W. Wolff (CA SBN 215819) [e-mail] Frank Albert (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 12390 El Camino Real San Diego, CA 92130 Telephone: [phone] Facsimile: [phone] Jennifer N. Scarpati (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 601 Lexington Avenue, 52nd Floor New York, NY 10022-4611 Telephone: [phone] Facsimile: [phone]

Howard G. Pollack (Admitted Pro Hac Vice) [e-mail] Shelley K. Mack (Admitted Pro Hac Vice) [e-mail] Jerry T. Yen (CA SBN 247988) [e-mail] Enrique D. Duarte (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 500 Arguello Street, Suite 500 Redwood City, CA 94063 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant GOOGLE INC.

CERTIFICATE OF SERVICE The undersigned hereby certifies that on March 8, 2011, a true and correct copy of DEFENDANT GOOGLE INC.'S UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMIT was served on all counsel of record for NORTHEASTERN UNIVERSITY and JARG CORPORATION in the manner agreed to by the parties, via an e-mail to: [e-mail]. /s/ Jennifer N. Scarpati Jennifer N. Scarpati

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Google has complied with the meet and confer requirements under Local Rule CV-7(h). Counsel for the parties conducted a meet and confer via email on March 8, 2011, and the present motion is unopposed. /s/ Jennifer N. Scarpati________ Jennifer N. Scarpati

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