`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`BLITZSAFE TEXAS, LLC,
`
`Plaintiffs
`
`v.
`
`TOYOTA MOTOR CORPORATION, ET AL,
`
`Defendants.
`
`
`
`Civil Action No. 2:15-cv-1274-JRG-
`RSP
`
`
`
`JURY TRIAL
`
`
`
`BLITZSAFE’S UNOPPOSED MOTION FOR LEAVE TO FILE A RESPONSE TO
`DEFENDANTS MOTION TO DISQUALIFY IN EXCESS OF PAGE LIMITS
`
`Plaintiff Blitzsafe moves for leave to exceed the page limitation set forth in Local Rule
`
`CV-7(a)(2) in filing their Response to Defendants’ Motion to Disqualify Plaintiff’s Counsel.
`
`Specifically, Blitzsafe moves to exceed the fifteen page limit and instead file a twenty-three page
`
`Response in order to address the Defendant’s motion. Further, the parties have agreed that
`
`should Toyota need additional pages for their Reply Blitzsafe will not oppose a Request from
`
`Toyota to exceed the page limit of its reply up to and including eight (8) pages. Toyota does not
`
`oppose the relief sought in this motion.
`
`1
`
`
`
`
`
`
`
`
`
`Case 2:15-cv-01274-JRG-RSP Document 173 Filed 09/29/16 Page 2 of 2 PageID #: 6032
`
`
`Dated: September 29, 2016
`
`Respectfully submitted,
`
`Samuel F. Baxter
`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`
`Alfred R. Fabricant
`Texas Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Lawrence C. Drucker
`Email: ldrucker@brownrudnick.com
`Texas Bar No. 2303089
`Peter Lambrianakos
`Texas Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: (212) 209-4800
`Facsimile: (212) 209-4801
`
`/s/ Jennifer Truelove
`Jennifer Truelove
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`was electronically filed with the CM/ECF system per LR 5.1, and that all interested parties are
`being served with a true and correct copy of these documents via the CM/ECF system on
`September 29, 2016..
`
`
`
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