United States of America v. Impulse Media Group Inc

Filing 15

Stipulated MOTION to File Overlength Briefs and Documents Under Seal by Plaintiff United States of America. Noting Date 8/29/2006. (Attachments: # 1 Proposed Order)(Hash, Lauren)

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United States of America v. Impulse Media Group Inc Doc. 15 Case 2:05-cv-01285-RSL Document 15 Filed 08/29/2006 Page 1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff United States of America and Defendant Impulse Media Group, Inc., by and through their undersigned counsel, hereby file this Joint Motion for Leave to File Overlength Briefs and to File Documents Under Seal in conjunction with the parties' Motions for Summary Judgment due September 5, 2006. This case presents matters of first impression regarding the Controlling the Assault of UNITED STATES OF AMERICA, Plaintiff, v. IMPULSE MEDIA GROUP, INC., a Washington corporation, Defendant. No. CV05-1285L JOINT MOTION FOR LEAVE TO FILE OVERLENGTH BRIEFS and TO FILE DOCUMENTS UNDER SEAL NOTE ON MOTION CALENDAR: August 29, 2006 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE Non-Solicited Pornography and Marketing Act of 2003 ("CAN-SPAM"), 15 U.S.C. § 7701 et seq. Consequently, Plaintiff and Defendant seek an enlargement of the number of pages permitted for briefs as set forth in Local Rule CR 7(e) in the following amounts: 1. Motion for Summary Judgment: 35 pages; 2. Opposition in Response: 35 pages; 3. Reply: 15 pages. The parties also seek permission for the United States to file under seal three exhibits to the United States' Motion for Summary Judgment pursuant to the Protective Order entered in MOTION TO FILE OVERLENGTH BRIEFS and TO FILE DOCUMENTS UNDER SEAL CV05-1285L Department of Justice P.O. Box 386 Washington, DC 20044 (202) 353-1991 -1- Dockets.Justia.com Case 2:05-cv-01285-RSL Document 15 Filed 08/29/2006 Page 2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 this case (Docket # 10). These three exhibits have been marked Confidential by the Defendant due to personal identifying information contained in the exhibits. Dated: August 29, 2006 CarpeLaw PLLC s/ Robert S. Apgood Pro Hac Vice 2400 NW 80th Street #130 Seattle, WA 98117-4449 Telephone: (206) 624-2379 Facsimile: (206) 784-6305 E-mail: rob@carpelaw.com Lauren E. Hash s/ Lauren E. Hash Trial Attorney Department of Justice Office of Consumer Litigation P.O. Box 386 Washington, D.C. 20044 Tel: (202) 353-1991 Fax: (202) 514-8742 lauren.hash@usdoj.gov MOTION TO FILE OVERLENGTH BRIEFS and TO FILE DOCUMENTS UNDER SEAL CV05-1285L -2- Department of Justice P.O. Box 386 Washington, DC 20044 (202) 353-1991

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