AdvanceMe Inc v. RapidPay LLC

Filing 161

MOTION for Leave to File Excess Pages by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order Granting Unopposed Motion To File Opposition To Motion To Compel In Excess of Page Limit)(Matz, Robert)

AdvanceMe Inc v. RapidPay LLC

Doc. 161

Case 6:05-cv-00424-LED

Document 161

Filed 11/28/2006

Page 1 of 3

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

ADVANCEME, INC., Plaintiff, v. RAPIDPAY LLC, FIRST FUNDS LLC, MERCHANT MONEY TREE, INC., REACH FINANCIAL, LLC, and FAST TRANSACT, INC. d/b/a SIMPLE CASH, Defendants.

ADVANCEME, INC., Plaintiff, v. AMERIMERCHANT, LLC, Defendant.

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CASE NO. 6:05-CV-424 (LED ­ JDL)

CASE NO. 6:06-CV-082 (LED ­ JDL)

JURY TRIAL DEMANDED

PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE OPPOSITION TO MOTION TO COMPEL IN EXCESS OF PAGE LIMIT

Plaintiff, AdvanceMe, Inc., requests this Court for leave to file its Opposition To Defendants' Motion To Compel in excess of the ten page limit. AdvanceMe, Inc. requests that this Court allow it to exceed the fifteen page limit by nine 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.
MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL

CASE NO.6:05-CV-424 CASE NO.6:06-CV-082

Dockets.Justia.com

Case 6:05-cv-00424-LED

Document 161

Filed 11/28/2006

Page 2 of 3

Therefore, AdvanceMe, Inc. respectfully requests that this Court grant it leave to file its Opposition To Defendants' Motion To Compel in excess of the page limits previously set by this Court. Counsel for AdvanceMe, Inc. has conferred with Joseph Gray, counsel for Defendants. Defendants have agreed to this motion. An Order reflecting same is attached for the Court's convenience. Respectfully submitted, DATED: November 28, 2006 By: ___________/s/ Robert C. Matz____________ PAUL, HASTINGS, JANOFSKY & WALKER LLP Ronald S. Lemieux (CA Bar No. 120822) (Admitted Pro Hac Vice) Michael N. Edelman (CA Bar No. 180948) (Admitted Pro Hac Vice) Vidya R. Bhakar (CA Bar No. 220210) (Admitted Pro Hac Vice) Robert C. Matz (CA Bar No. 217822) (Admitted Pro Hac Vice) Shanée Y. Williams (CA Bar No. 221319) (Admitted Pro Hac Vice) Five Palo Alto Square, Sixth Floor Palo Alto, CA 94306-2155 Telephone: [phone] Telecopier: [phone] Email: [e-mail] IRELAND, CARROLL & KELLEY, P.C. Otis W. Carroll, Attorney-in-Charge State Bar No. 03895700 Deborah Race State Bar No. 16448700 6101 South Broadway, Suite 500 Tyler, TX 75703 Telephone: [phone] Facsimile: 903-581-1071 Email: [e-mail] ATTORNEYS FOR PLAINTIFF ADVANCEME, INC.

MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL

CASE NO.6:05-CV-424 CASE NO.6:06-CV-082

Case 6:05-cv-00424-LED

Document 161

Filed 11/28/2006

Page 3 of 3

CERTIFICATE OF CONFERENCE The undersigned counsel for AdvanceMe, Inc. has conferred with Joseph Gray, counsel for Defendants. Defendants have agreed to this motion.

/s/ Robert C. Matz

CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served a copy of this document via the court's CM/ECF system pursuant to Local Rule cv-5(a)(3) on this the 28th day of November, 2006. Any other counsel of record will be served by first class mail on this same date.

/s/ Rose Jones-Shine

MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' MOTION TO COMPEL

CASE NO.6:05-CV-424 CASE NO.6:06-CV-082