Free Motion for Leave to File Excess Pages - District Court of Connecticut - Connecticut

Case 3:00-cv-00705-CFD Document 134 Filed 02/17/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
M--W , Master File N 0. 3:00CV—705 (CFD)
IN RE: PE CORPORATION )
SECURITIES LITIGATION g February 16, 2005
)
CONSENTED TO MOTION FOR LEAVE TO INCREASE PAGE LIMITS
Plaintiffs David Berlin and Vinh Vuong (‘°plaintiffs") hereby move pursuant to
Local Rule 7(a) for an increase to the page limits for plaintiffs’ memorandum in
opposition to Defendants’ Motion for Summary Judgment ("defendants’ motion") and
defendants’ reply memorandum in further support of defendants’ motion. Defendants PE
Corporation et al consent to the granting of this motion. In support of this motion, the
parties represent:
l. On December 2l , 2004, defendants liled their motion for summary
judgment, which plaintiffs intend to oppose. Plaintiffs’ memorandum in opposition to
defendants’ motion is due to be tiled with the Court by February l6, 2005.
2. Defendants’ motion for summary judgment is 40 pages in length and
raises numerous factual and legal issues. In addition, defendants have referenced 55
exhibits in their motion, totaling hundreds of pages of documentary evidence. In order
for plaintiffs to properly address the arguments raised in defendants’ motion, plaintiffs
require a short extension ofthe page limit set forth in Local Rule 7(a). Accordingly,
plaintiffs request leave to file a ·46—page memorandum in opposition to defendants’
motion. Defendants’ reply brief, which is due to be ililed on March 23, 2005, will be no
longer than l5 pages.

Case 3:00-cv—00705—CFD Document 134 Filed 02/17/2005 Page 2 of 3
3. Plaintiffs counsel contacted dcfendants’ counsel concerning this motion
and they have consented to the granting of such motion.
RELIEF REQUESTED
Based on the foregoing, the plaintiffs respectfully request that the Court issue an
Order permitting plaintiffs to file a memorandum in opposition to Cl€fCl’1dEl11fSi motion for
summary judgment of up to 46 pages and permitting defendants to lile a reply
memorandum that is no longer than l5 pages.
Respectfully submittvevdd. 1
VW iw in ai `€s`I;;·$'*n{•*’ § Iva {
By: i _“ert·rt1rWr-~»5_
David A. Slossberg (CTl3l l6)
Brian C, Fournier (CTl6272)
HURWITZ, SAGARIN & SLOSSBERG,
LLC
147 North Broad Street
P.O. Box 112
Milford, CT 06460
(203) 877-8000
Liaison Counsel for Lead Plaintiffs
Sanford P. Dumain (CT08 138)
Lee A. Weiss (pro here vice)
Carlos F. Ramirez (pm here vice)
MILBERG WEISS BERSHAD &
SCHULMAN LLP
_ One Pennsylvania Plaza
New York, NY 10119
(2l2) 594-5300
Lead Counsel for Lead Plaintiffs

Case 3:00-cv—00705—CFD Document 134 Filed O2/17/2005 Page 3 of 3
CERTIFICATION
This is to certify that a copy of the foregoing Consented to Motion for Leave to
lncreasc Page Limits was served by federal express, on February 16, 2005, on the
following:
Stanley A. Twardy, Jr., Esq. Michael J. Chepiga, Esq.Robert A.
Thomas D. Goldberg, Esq. Bourque, Esq.
Terence .l. Gallagher, Esq. William M. Regan, Esq.
Day, Berry & Howard LLP Simpson Thacher & Bartlett LLP
One Canterbury Green 425 Lexington Avenue
Stamford, CT 06901 New York, NY l 00] 7
Counsel for Defendants Counsel for Defendants
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Brian C. Fournier