Castro v. Entrepreneur Media, Inc.
Filing
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Unopposed MOTION for Leave to Exceed Page Limitation by Entrepreneur Media, Inc.. (Attachments: # 1 Proposed Order)(Barber, William)
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION
DANIEL R. CASTRO,
Plaintiff,
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v.
ENTREPRENEUR MEDIA, INC.,
Defendant.
ENTREPRENEUR MEDIA, INC.,
Counterclaimant,
v.
DANIEL R. CASTRO,
Counterdefendant.
Cause No. 1-10-CV-000695-LY
Hon. Lee Yeakel
DEFENDANT’S UNOPPOSED MOTION FOR LEAVE
TO FILE OPPOSITION IN EXCESS OF PAGE LIMIT
Defendant and Counterclaimant Entrepreneur Media, Inc. (“Defendant”) moves for leave
to file its Combined Opposition to Plaintiff’s Motions to Dismiss (“Opposition”), which is in
excess of the 10-page limitation set forth in the Local Rule CV-7(d). Defendant requires a
moderate number of additional pages to address the numerous issues raised in Plaintiff’s Rule
12(b)(1) and 12(b)(6) Motions to Dismiss.
Because Defendant has chosen to combine its
Oppositions in the interests of efficiency, Defendant requests a total of 16 pages for its
Opposition.
CERTIFICATE OF CONFERENCE
Prior to filing this motion, counsel for Defendant conferred by email with Plaintiff
concerning this motion. Plaintiff does not oppose the motion.
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Respectfully submitted,
Dated: June 23, 2011
By: /s/ William G. Barber
William G. Barber
PIRKEY BARBER LLP
Texas State Bar No. 01713050
600 Congress Avenue, Suite 2120
Austin, TX 78701
(512) 322-5200 / (512) 322-5201 Fax
Perry J. Viscounty (Admitted Pro Hac Vice)
LATHAM & WATKINS LLP
650 Town Center Drive, 20th Floor
Costa Mesa, CA 92626
(714) 540-1235 / (714) 755-8290 Fax
Jennifer L. Barry (Admitted Pro Hac Vice)
LATHAM & WATKINS LLP
600 West Broadway, Suite 1800
San Diego, CA 92101
(619) 236-1234 / (619) 696-7419 Fax
Attorneys for Defendant/Counterclaimant
ENTREPRENEUR MEDIA, INC.
CERTIFICATE OF SERVICE
I hereby certify that on June 23, 2011, I electronically filed the foregoing with the Clerk
of Court using the CM/ECF system which will send notification of such filing to the following:
Daniel R. Castro
CASTRO & BAKER, LLP
7800 Shoal Creek Blvd., Suite 100N
Austin, TX 78757
/s/ William G. Barber
William G. Barber
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