AdvanceMe Inc v. RapidPay LLC

Filing 105

MOTION for Leave to File Excess Pages Unopposed by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order # 2 Exhibit A - Plaintiff's Opening Claim Construction Brief)(Race, Deborah)

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AdvanceMe Inc v. RapidPay LLC Doc. 105 Case 6:05-cv-00424-LED Document 105 Filed 09/14/2006 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ADVANCEME, INC. VS. RAPDIPAY, LLC, et al § § § § § Civil Case No. 6:05-CV-424 Davis/Love PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE OPENING CLAIM CONSTRUCTION BRIEF IN EXCESS OF PAGE LIMIT TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, AdvanceMe, Inc., requests the Court for leave to file its Opening Claim Construction Brief in excess of the thirty page limit. AdvanceMe, Inc. requests that this Court allow it to exceed the thirty page limit by ten pages, excluding attachments. Plaintiff requests the additional pages because it has determined that the current length of the brief is necessary to best present its argument to the Court. Therefore, AdvanceMe, Inc. respectfully requests that this Court grant it leave to file its Opening Claim Construction Brief in excess of the page limits previously set by this Court. Counsel for AdvanceMe, Inc. has conferred with Doug McSwane, counsel for Defendants. Defendants have agreed to this motion. An order reflecting same is attached for the Court's convenience. Respectfully submitted, /s/ Deborah Race Otis Carroll Texas State Bar No. 03895700 Deborah Race Texas State Bar No. 16448700 IRELAND, CARROLL & KELLEY, P.C 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600 Fax: (903) 581-1071 Email: Fedserv@icklaw.com Dockets.Justia.com Case 6:05-cv-00424-LED Document 105 Filed 09/14/2006 Page 2 of 2 Ronald S. Lemieux Vid R. Bhakar Robert C. Matz Shanee Williams Michael Edelman PAUL, HASTINGS, JANOFKSY & WALKER, LLP Five Palo Alto Square, Sixth Floor Palo Alto, CA 94306-1800 Tel: (650) 320-1800 Fax: (650) 340-1900 Email: ronlemieux@paulhastings.com ATTORNEYS FOR PLAINTIFF ADVANCEME, INC. 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). Any other counsel of record or parties will be served by facsimile transmission and/or first class mail this 14th day of September, 2006. /s/ Deborah Race CERTIFICATE OF CONFERENCE The undersigned counsel for AdvanceMe, Inc. has conferred with Doug McSwane, counsel for Defendants. Defendants have agreed to this motion. /s/ Deborah Race

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