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

Case 3:00-cv—OO705—CFD Document 153 Filed 07/O1/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
IN RE: PE CORPORATION SECURITIES Master File No. 3;00CV—705 (CFD)
LITIGATION :
July l, 2005
NOTICE OF MOTION FOR LEAVE TO FILE
SUPPLEMENTAL MEMORANDUM OF LAW
PLEASE TAKE NOTICE that Plaintiffs David Berlin and Vinh Vuong hereby move this
Court for leave to file a supplemental memorandum of law in further support of their prior
submission in opposition to Defendants’ Motion for Summary Judgment (the "Summary
Judgment Opposition").
Plaintiffs submit that when they filed their Summary Judgment Opposition on February
l5, 2005, Plaintiffs’ Motion to Compel the Testimony of Dr. Francis Collins (the "Motion to
Compel") was pending before this Court. Plaintiffs referenced their pending Motion to Compel
in their Summary Judgment Opposition, indicating that plaintiffs intended to use Dr. Collins’
testimony to support their opposition in the event the Court granted plaintiffs’ Motion to
Coinpel. The Court granted plaintiffs’ Motion to Compel and plaintiffs deposed Dr. Collins on
June l 5 , 2005. Plaintiffs now move to supplement their Summary Judgment Opposition with the
attached Memorandum of Law concerning Dr. Collins’s testimony.

Case 3:00-cv—OO705—CFD Document 153 Filed 07/O1/2005 Page 2 of 2
BY- T 1
J Da fw »**a agar QV 289)
avid A. S1oss cr}_g,( T13116)
` rian C. Foum cr (CT16272)
HU · WITZ, SAGARIN
& i ossBERG, LLC
r N. Broad Street, P.O. Box 112
Milford, CT 06460
(203) 877 -- 8000
Plaintws ’ Liaison Counsel
Sanford P. Dumaiii (CTO8138)
Lee A, Weiss (CT21345)
Shannon L. Hopkins
MILBERG Wmss BERSHAD
& SCHULMAN LLP
One Pennsylvania Plaza
New York, NY 101 19
(212) 594-5300
1 Plaintmf Lead Counsel