AdvanceMe Inc v. RapidPay LLC

Filing 220

MOTION for Leave to File Excess Pages in its Opposition to Defendants' Partial Summary Judgment Motion by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order)(Matz, Robert)

AdvanceMe Inc v. RapidPay LLC

Doc. 220

Case 6:05-cv-00424-LED

Document 220

Filed 03/30/2007

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.

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CASE NO. 6:05-CV-424 (LED ­ JDL)

PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE AN OPPOSITION TO DEFENDANTS' PARTIAL SUMMARY JUDGMENT MOTION OF PATENT INVALIDITY IN EXCESS OF PAGE LIMIT Plaintiff, AdvanceMe, Inc., respectfully requests this Court for leave to file its Opposition To Defendants' Motion for Partial Summary Judgment of Patent Invalidity in excess of the thirty (30) page limit allowed by Local Rule CV-7. AdvanceMe, Inc. requests that this Court allow it to exceed the thirty-page limit by 10 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. Counsel for AdvanceMe, Inc. has conferred with Joseph Gray, counsel for Defendants. Defendants have stated that they do not oppose this motion.

MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' MOTION FOR PARTIAL SUMMARY JUDGMENT

CASE NO.6:05-CV-424

Dockets.Justia.com

Case 6:05-cv-00424-LED

Document 220

Filed 03/30/2007

Page 2 of 3

A proposed Order is attached for the Court's convenience. Dated: March 30, 2007 Respectfully submitted, 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 FOR PARTIAL SUMMARY JUDGMENT

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CASE NO.6:05-CV-424

Case 6:05-cv-00424-LED

Document 220

Filed 03/30/2007

Page 3 of 3

CERTIFICATE OF CONFERENCE The undersigned counsel for AdvanceMe, Inc. has conferred with Joseph Gray, counsel for Defendants. Defendants have stated that they do not oppose this motion.

/s/ Robert C. Matz 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 30th day of March, 2007. Any other counsel of record will be served by first-class mail on this same date. /s/ Robert C. Matz Robert C. Matz
LEGAL_US_W # 55948800.1

MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' MOTION FOR PARTIAL SUMMARY JUDGMENT

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CASE NO.6:05-CV-424