Free Redacted Document - District Court of Delaware - Delaware

I n Case 1 :04-cv-01488-JJF Document 85 Filed 08/O1/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ROBERT V. TOWNES, IV, A )
Individually and on behalf of )
all persons similarly situated, )
)
Plaintiff] ) C.A. 04-1488-JJF
)
vs. )
) CLASS ACTION
TRANS UNION, LLC, AND ) REDACTED VERSION
TRUELINK, INC., ) Original Filing Date: July 30, 2007
Defendants. ) Redacted Filing Date: August 1, 2007
DEFENDANTS’ MOTION FOR LEAVE TO FILE THE ATTACHED SUPPLEMENTAL
BRIEF IN OPPOSITION TO MOTION FOR LEAVE TO INTERVENE
Defendants Trans Union LLC and TrueLink, Inc. (now known as TransUnion
Interactive, Inc. and referred to herein as "TrueLink") (collectively, the "Def`endants") move for
leave to file their Supplemental Brief in Opposition to Motion for Leave to Intervene attached
hereto as Exhibit 1. Defendants request leave to file a supplemental brief in order to advise the
Court of facts only obtained since Defendants filed their original opposition brief and which are
relevant to the pending Steven and Melody Millett’s (the “Proposed Intervenors") Motion for
Leave to Intewene in the above-captioned action in order to challenge the class settlement
reached here.
First, the federal district court in the related Eguifaxfli air Isaac Litigationl has
recently granted final approval to a nationwide class settlement agreement that is nearly identical
to the nationwide class settlement agreement reached by the parties in the above—captioned action
and preliminarily approved by this Court. [REDACTED]
1 All undefined terms contained herein which were defined in Def`endants’ original Brief in
Opposition to Motion for Leave to Intervene have the same meaning as used in the earlier
brief.

Case 1:04-cv-01488-JJF Document 85 Filed 08/O1/2007 Page 2 of 3 p
[REDACTED] ‘
The Defendants request leave to file the attached eight-page supplemental brief in
order to provide this Court with these new facts, which are directly relevant to arguments and
facts originally cited in Defendants’ initial Brief in Opposition to Motion for Leave to Intervene.
Pursuant to D. Del. LR 7.1.1, counsel for the Defendants certifies that the subject
of this motion has been discussed with counsel for plaintiff Robert V. Townes IV and that e
Townes does not oppose the Motion. In addition, pursuant to D. Del. LR 7.1.1, counsel for the
Defendants certifies that the subject of this motion has been discussed with counsel for the
Proposed Intervenors and that the Proposed Intervenors oppose this Motion. · _ _
WHEREFORE, Defendants Trans Union `LLC and Tn.1eLinl<, Inc. (now known as
TransUnion Interactive, Inc.) respectfully request that this Court enter an Order granting
Defendants leave to file the attached Supplemental Brief in Opposition to Motion for Leave to
Intervene.
MORRIS, NICHOLS, ARSHT 8; TUNNELL LLP
Wl
Jay . Moffitt (#4742)
1201 N. Market Street
Wihnington, DE 19801
(302) 658-9200 p
Attorneys far Defendants
2

Case 1:04-cv-01488-JJF Document 85 Filed 08/O1/2007 Page 3 of 3
OF COUNSEL:
Michael C. O’Nei1
Paula D. Friedman
DLA Piper US LLP
203 North LaSalle Street, Suite 1900
— Chicago, IL 60601-1293
(312) 368-4000
July 30, 2007
3