AdvanceMe Inc v. RapidPay LLC

Filing 247

MOTION for Leave to File Excess Pages In Opposition to Defendants' Second Motion for Partial Summary Judgment of Patent Invalidity in Excess of Page Limit by AdvanceMe Inc. (Attachments: # 1 Text of Proposed Order Granting Leave to File Opposition to Defendants' Second Motion for Partial Summary Judgment of Patent Invalidity in Excess of Page Limit)(Williams, Shanee)

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AdvanceMe Inc v. RapidPay LLC Doc. 247 Case 6:05-cv-00424-LED Document 247 Filed 05/02/2007 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. § § § § § § § § § § § § § § CASE NO. 6:05-CV-424 (LED ­ JDL) PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO FILE AN OPPOSITION TO DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT OF PATENT INVALIDITY IN EXCESS OF PAGE LIMIT Plaintiff, AdvanceMe, Inc. ("AdvanceMe"), respectfully requests leave to file its Opposition To Defendants' Second Motion for Partial Summary Judgment of Patent Invalidity in excess of the cumulative sixty (60) page limit allowed by Local Rule CV-7(a)(1). AdvanceMe requests that this Court allow it to exceed the sixty-page limit by three (3) 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 Willem G. Schuurman, 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' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT CASE NO.6:05-CV-424 Dockets.Justia.com Case 6:05-cv-00424-LED Document 247 Filed 05/02/2007 Page 2 of 3 A proposed Order is attached for the Court's convenience. Dated: May 2, 2007 Respectfully submitted, By: /s/ Shanée Y. Williams Shanée Y. Williams 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. 221310) (Admitted Pro Hac Vice) Five Palo Alto Square, Sixth Floor Palo Alto, CA 94306-2155 Telephone: (650) 320-1800 Telecopier: (650) 320-1900 Email: ronlemieux@paulhastings.com 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: 903-561-1600 Facsimile: 903-581-1071 Email: fedserv@icklaw.com ATTORNEYS FOR PLAINTIFF ADVANCEME, INC. MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT -2- CASE NO.6:05-CV-424 Case 6:05-cv-00424-LED Document 247 Filed 05/02/2007 Page 3 of 3 CERTIFICATE OF CONFERENCE The undersigned counsel for AdvanceMe, Inc. has conferred with Willem G. Shcuurman, counsel for Defendants. Defendants have stated that they do not oppose this motion. /s/ Shanée Y. Williams Shanée Y. Williams 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 2nd day of May, 2007. Any other counsel of record will be served by first-class mail on this same date. /s/ Shanée Y. Williams Shanée Y. Williams LEGAL_US_W # 56146692.1 MOTION TO FILE IN EXCESS OF PAGE LIMIT RE ADVANCEME'S OPPOSITION TO DEFENDANTS' SECOND MOTION FOR PARTIAL SUMMARY JUDGMENT -3- CASE NO.6:05-CV-424

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