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QVC, INC. v. SCHIEFFELIN Et Al - Document No. 21

RESPONSE to Motion re 12 MOTION to Dismiss Amended Complaint and MOTION for Leave to File Second Amended Complaint filed by QVC, INC..Memorandum, Certificate of Service. (Attachments: # 1 Memorandum of Law# 2 Exhibit A# 3 Certificate of Service# 4 Text of Proposed Order Proposed Order)(METZ, NATHANIEL) Modified on 3/16/2007 (np). 2:2006cv04231 Pennsylvania Eastern District Court

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113 views1 page

QVC, INC. v. SCHIEFFELIN Et Al - Document No. 21

RESPONSE to Motion re 12 MOTION to Dismiss Amended Complaint and MOTION for Leave to File Second Amended Complaint filed by QVC, INC..Memorandum, Certificate of Service. (Attachments: # 1 Memorandum of Law# 2 Exhibit A# 3 Certificate of Service# 4 Text of Proposed Order Proposed Order)(METZ, NATHANIEL) Modified on 3/16/2007 (np). 2:2006cv04231 Pennsylvania Eastern District Court

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QVC, INC. v. SCHIEFFELIN et al Doc.

21
Case 2:06-cv-04231-TON Document 21 Filed 03/15/2007 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF PENNSYLVANIA
____________________________________
:
QVC, INC. : CIVIL ACTION
:
Plaintiff, :
:
v. : NO. 06-cv-4231(TON)
:
STACEY SCHIEFFELIN, :
DAVID SCHIEFFELIN, :
and MODELS PREFER, LTD., :
:
Defendants. :
____________________________________:

MOTION OF PLAINTIFF QVC, INC. FOR


LEAVE TO FILE SECOND AMENDED COMPLAINT

Plaintiff, QVC, Inc., by and through its undersigned counsel, respectfully moves this

Court for Order granting Plaintiff leave to file a Second Amended Complaint for the reasons set

forth in the accompanying memorandum of law which is incorporated herein by reference.

SAUL EWING LLP

/s/ Nathaniel Metz


By:__________________________
Nathaniel Metz, Esquire
(215) 972-8385
(215) 972-2282 (Telefacsimile)
[email protected]
Centre Square West
1500 Market Street, 38th Floor
Philadelphia, PA 19102-2186

Attorneys for Plaintiff, QVC, Inc.

Dockets.Justia.com

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