Northeastern University et al v. Google, Inc.,

Filing 182

Unopposed MOTION for Leave to File Excess Pages to Plaintiffs' Opposition to Daubert Motion to Exclude Jarosz Testimony by Jarg Corporation, Northeastern University. (Attachments: # 1 Text of Proposed Order)(Glauser, Nicole)

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Northeastern University et al v. Google, Inc., Doc. 18 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION NORTHEASTERN UNIVERSITY and JARG CORPORATION Plaintiffs, Case No. 2:07-CV-486-CE v. JURY TRIAL DEMANDED GOOGLE INC. Defendant. PLAINTIFFS' UNOPPOSED MOTION FOR LEAVE TO EXCEED THE PAGE LIMIT Plaintiffs Northeastern University and Jarg Corporation ("Plaintiffs") file this Unopposed Motion for Leave to Exceed Page Limit respectfully requesting leave to exceed the page limit set forth in Local Rule CV-7(a)(3)(B) for Plaintiffs' Response ("Response") to Defendant's Daubert Motion to Exclude the Expert Testimony of John Jarosz ("Motion") (Dkt. 181). Plaintiffs seek leave to file their Response, which is 22 pages in length excluding exhibits. The Response exceeds the page limit set forth in Local Rule CV-7(a)(2) by 7 pages, excluding exhibits. The additional pages are necessary because of the number of issues raised in Google's Motion, which likewise exceeded the page limit set forth in Local Rule CV-7(a)(2), that require responsive briefing, the complexity of the issues, and the severity of the relief sought, including, inter alia, preclusion Plaintiffs' damages expert's, John C. Jarosz, opinions and testimony. Plaintiffs' counsel has conferred with counsel for Google, and Google's counsel is not opposed to this motion. Dated: March 28, 2011 Respectfully submitted, /s/ Nicole E. Glauser Otis W. Carroll, Jr. (Tx Bar No. 03895700) Collin Maloney (Tx Bar No. 00794219) IRELAND CARROLL & KELLEY 6101 S Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600 Fax: (903) 581-1071 Constance S. Huttner VINSON & ELKINS LLP 666 Fifth Avenue, 26th Floor New York, New York 10103 Tel: (212) 234-0040 Fax: (212) 237-0100 William B. Dawson (Tx Bar No. 05603600) GIBSON, DUNN & CRUTCHER 2100 McKinney Avenue, Suite 1100 Dallas, Texas 75201-6912 Tel: (214) 698-3132 Fax: (214) 571-2900 David B. Weaver (Tx Bar No. 00798576) Christopher V. Ryan (Tx Bar No. 24037412) Michael Valek (Tx Bar No. 24044028) Stephen C. Stout (Tx Bar No. 24060672) James D. Shead (Tx Bar No. 24070609) Nicole E. Glauser (Tx Bar No. 24050694) Zeke DeRose, III (Tx Bar No. 24057421) VINSON & ELKINS LLP 2801 Via Fortuna, Suite 100 Austin, Texas 78746 Tel: (512) 542-8400 Fax: (512) 236-3338 Bernard C. Shek (CA Bar No. 191365) VINSON & ELKINS LLP 525 University Avenue, Suite 410 Palo Alto, California 94301-1918 Tel: (650) 687-8200 Fax: (650) 618-1970 ATTORNEYS FOR PLAINTIFFS NORTHEASTERN UNIVERSITY AND JARG CORPORATION - 2- CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Plaintiffs 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 26, 2011, and the present motion is unopposed. /s/ Nicole E. Glauser Nicole E. Glauser CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). All other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email and/or fax, on this the 28th day of March 2011. /s/ Nicole E. Glauser Nicole E. Glauser - 3-

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