Data Scape Limited v. Dropbox, Inc.

Western District of Texas, txwd-6:2019-cv-00023

Unopposed MOTION for Leave to Exceed Page Limitation by Dropbox, Inc.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION Data Scape Limited Plaintiff, v. Civil Action No. 6:19-cv-00023-ADA Dropbox, Inc. Defendant. UNOPPOSED MOTION TO EXPAND PAGE LIMIT FOR MOTION TO TRANSFER VENUE TO: THE HONORABLE ALAN D. ALBRIGHT, UNITED STATES DISTRICT JUDGE: Comes Now, Dropbox, Inc. ("Dropbox") and files its Unopposed Motion to expand page limit for Motion to Transfer Venue to the United States District Court for the Northern District of California and as grounds therefore would respectfully show the Court as follows. Dropbox, by this motion, requests no more than twenty pages for its Motion to Transfer. Dropbox has endeavored to efficiently, and without unnecessary repetition or hyperbole, cover the law governing its Motion to Transfer and also plead and prove the relevant facts in a spare and appropriate fashion. If Dropbox was bringing a dispositive Motion to Dismiss for improper venue, the page limit under the local rules would be the requested twenty pages. There is no reason Dropbox's technically nondispositive motion to transfer should be allowed any fewer pages. This Motion to Transfer is not brought to make extra work for the parties or the Court but instead so that the Motion's subject matter can be fairly and properly presented. As the certificate of conference below states, in seeking Plaintiff's agreement to this Motion, Dropbox agreed not UNOPPOSED MOTION TO EXPAND PAGE LIMIT FOR MOTION TO TRANSFER VENUE PAGE 1 to oppose an enlargement of Plaintiff's response pages from ten pages to twenty and its response time from seven days to fourteen. Respectfully submitted, By: /s/ J. Stephen Ravel J. Stephen Ravel Texas State Bar No. 16584975 KELLY HART & HALLMAN LLP 303 Colorado, Suite 2000 Austin, Texas 78701 Tel: (512) 495-6400 Fax: (512) 495-6401 Email: steve.ravel@kellyhart.com Gregory H. Lantier (Pro Hac Vice filed) DC Bar No. 492043 Virginia State Bar No. 65657 New York State Bar No. 4823217 WILMER HALE LLP 1875 Pennsylvania Avenue Washington DC 20006 Tel: (202) 663-6327 Email: gregory.lantier@wilmerhale.com Monica Grewal (Pro Hac Vice to come) Massachusetts State Bar No. 659449 Connecticut State Bar No. 414009 WILMER HALE LLP 60 State Street Boston, Massachusetts 02109 Email: monica.grewal@wilmerhale.com Yvonne Lee (Pro Hac Vice filed) Massachusetts State Bar No. 687623 WILMER HALE LLP 60 State Street Boston, Massachusetts 02109 Tel: (617) 526-6692 Email: yvonne.lee@wilmerhale.com UNOPPOSED MOTION TO EXPAND PAGE LIMIT FOR MOTION TO TRANSFER VENUE PAGE 2 Alexis Pfeiffer (Pro Hac Vice filed) California State Bar No. 312007 WILMER HALE LLP 950 Page Mill Road Palo Alto, California 94304 Tel: (650) 858-6052 Email: alexis.pfeiffer@wilmerhale.com ATTORNEYS FOR DEFENDANT DROPBOX, INC. CERTIFICATE OF CONFERENCE Counsel for the parties conferred by telephone on April 22, 2019. Plaintiff does not oppose the relief sought provided Defendant does not oppose an enlargement of Plaintiff's response pages from ten to twenty and its response time from seven days to fourteen days. Defendant does not oppose either the page limit or time extension Plaintiffs seeks. CERTIFICATE OF SERVICE The undersigned certifies that on April 24, 2019 all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system pursuant to Local Rule CV-5(a)(3)(A). /s/ J. Stephen Ravel J. Stephen Ravel UNOPPOSED MOTION TO EXPAND PAGE LIMIT FOR MOTION TO TRANSFER VENUE PAGE 3