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

E360INSIGHT, 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, aka
THE SPAMHAUS PROJECT LTD,
Defendant

MOTION FOR EXTENSION OF DISCOVERY SCHEDULE

Plaintiffs, e360Insight, LLC and David Linhardt (collectively Plaintiffs), by and through their attorneys, Synergy Law Group, LLC, respectfully requests that this Court grant Plaintiffs’ Motion For Extension Of Discovery Schedule. In support of this motion Plaintiffs state:

1. On December 5, 2007, this Court ordered that all discovery is to be completed by February 28, 2008. (ECF No. 138).

2. Both parties have exchanged written discovery.

3. In preparing responses to the discovery and realizing that there will be a need for depositions and subpoenas to third parties, Plaintiff proposes extending the current discovery schedule.

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4. Pursuant to Local Rule 37.2, the parties conferred in person on February 5, 2008 and discussed extending the current discovery schedule.

5. Consistent with the attached draft Order, Plaintiffs request that the Court extend the discovery schedule as follows: responses by both parties to all written discovery shall be completed by February 29, 2008; any motions to compel shall be filed by March 31, 2008; all written discovery closes on April 17, 2008; Plaintiffs to disclose experts, if any, by March 31, 2008; Defendant to disclose experts by April 14, 2008; all oral discovery closes on April 28, 2008.

6. This motion is not brought to cause undue delay but rather to have the discovery schedule reflect the time required to conduct the necessary discovery.

Respectfully submitted,

e360Insight LLC and David Linhardt

By: /s/ Daniel J. Peters

One of Their Attorneys
Bartly J. Loethen (6225484)
Joseph L. Kish (6197916)
Daniel J. Peters (6272859)
Synergy Law Group, LLC
730 West Randolph, 6th Floor
Chicago, Illinois 60661
Telephone: (312) 454-0015
Facsimile: (312) 454-0261

Attachment	Date	Size
MotExtDisco.pdf	06/28/09 1:05 pm	36.98 KB