SpamSuite.com

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

e360 INSIGHT, LLC, an Illinois Limited Liability Company, and DAVID LINHARDT, an individual,
Plaintiffs,

v.

THE SPAMHAUS PROJECT, a company limited by guarantee and organized under the laws of England, a/k/a THE SPAMHAUS PROJECT, LTD.,
Defendant.

DEFENDANT’S MOTION FOR LEAVE TO FILE INSTANTER A STATUS REPORT ON SUGGESTED DEPOSITION

Defendant The Spamhaus Project (“Spamhaus”),1 by and through its attorneys Jenner & Block LLP, respectfully moves this Court for the entry of an order granting Spamhaus leave to file instanter the 4-page Status Report attached as Exhibit A. In support of this motion, Spamhaus states that the parties have agreed that the voluntary telephonic deposition of Steve Linford should not proceed because Plaintiffs’ counsel was not interested in taking the deposition within the scope of Steve Linford’s offer to provide testimony.

[1 Defendant expressly objects to this Court’s jurisdiction over The Spamhaus Project because Defendant is based solely in the United Kingdom and does not conduct or transact business in Illinois. Moreover, Defendant reserves its arguments based on Plaintiffs’ failure to properly effect service of process.]

Because Your Honor suggested that Plaintiffs accept Steve Linford’s prior offer to sit for a telephonic deposition, Spamhaus respectfully desired to advise the Court, prior to the continued hearing date, that the deposition did not proceed and the reasons why it did not proceed.

-2-
Respectfully submitted,

THE SPAMHAUS PROJECT
Dated: August 21, 2007

By: s/David Jiménez-Ekman _________

Craig C. Martin
David Jiménez-Ekman
Carrie A. Fino

JENNER & BLOCK LLP
330 North Wabash Avenue
Chicago, IL 60611
Telephone: (312) 222-9350
Facsimile: (312) 527-0484

Attachment	Date	Size
MotionLeaveStatusReport2.pdf	08/23/07 3:47 pm	21.42 KB