2 (collectively the “Individual Defendants”
Post# of 43066
Posted On: 09/25/2012 1:42:51 AM
2
(collectively the “Individual Defendants”) filed their joint motion to dismiss along with the
Individual Defendants’ Memorandum In Support Of Their Motion To Dismiss The Complaint(the “Individual Defendants’ Joint Brief”).The Individual Defendants’ Joint Brief consists of a thirty-page, four-part, highly fact-intensive argument. Each of the four headings has several sub-headings and pertains to multipledefendants. A thorough response will require an equally fact-intensive analysis, thereby justifying exceeding the usual page limits. Plaintiff requests leave to file a memorandum of lawin excess of twenty pages in order to comprehensively address each of the arguments presentedby the Individual Defendants. If this request is granted, Plaintiff’s memorandum of law will notexceed 30 pages.WHEREFORE, Plaintiff respectfully requests leave of Court to file a memorandum of upto thirty pages in length in support of his opposition to the Individual Defendants’ Motion ToDismiss Plaintiff’s Verified Shareholder Derivative Complaint.
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