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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`IN RE: AUTOMOTIVE PARTS
` Master File No. 12-md-02311
`ANTITRUST LITIGATION
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`Hon. Sean F. Cox
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`Mag. Judge R. Steven Whalen
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`THIS DOCUMENT RELATES TO:
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`ALL END-PAYOR ACTIONS
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`FINANCIAL RECOVERY SERVICES, LLC’S
`EX PARTE MOTION FOR EXTENSION OF PAGES
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`Financial Recovery Services, LLC (“FRS”), through its undersigned
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`counsel, brings this ex parte motion pursuant to L.R. 7.1(d)(3) to request leave to
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`file a reply brief of no more than 9 pages, excluding signatures, in support of its
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`Motion to Compel Acceptance and Processing of Vehicle Data (“Motion”).
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`In support of this motion, FRS states that this extension of the Local Rules’
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`page limit is necessary for FRS to respond fully to the issues raised in the
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`Response by counsel for End-Payor Plaintiffs (“Class Counsel”) to FRS’s Motion.
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`Specifically, additional pages are necessary to: (i) address and refute misleading
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`factual representations raised by Class Counsel; (ii) set forth an accurate factual
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`history of the claims submission process, which has been mischaracterized by
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`Class Counsel; and (iii) accurately summarize this Court’s prior orders, and the
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`Case 2:12-md-02311-SFC-RSW ECF No. 2123, PageID.38531 Filed 03/09/21 Page 2 of 4
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`pertinent procedural and administrative posture of this action, to ensure that this
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`Court has a full and fair picture of this case’s landscape.
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`FRS believes that addressing these matters is necessary to facilitate a just
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`decision on the Motion. As Class Counsel were permitted to file a Response to the
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`Motion exceeding the page limits set forth in the Local Rules by this Court’s order
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`dated March 4, 2021 [ECF 2121, PageID.38524], FRS requests the same
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`accommodation be extended to it in replying to that Response.
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`WHEREFORE, FRS respectfully requests that this Court grant it leave, on
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`an ex parte basis, to file its Reply in Support of its Motion to Compel Acceptance
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`and Processing of Vehicle Data of no more than 9 pages, excluding signatures.
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`Dated: March 9, 2021
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`Respectfully submitted,
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`
`
` /s/ Laura S. Faussié
`Jonathan T. Walton, Jr. (P32969)
`Michael P. Donnelly (P45221)
`Laura S. Faussié (P48933)
`FRASER TREBILCOCK
` DAVIS & DUNLAP, P.C.
`One Woodward Avenue, Suite 1550
`Detroit, MI 48226
`(313) 237-7300
`jwalton@fraserlawfirm.com
`mdonnelly@fraserlawfirm.com
`lfaussie@fraserlawfirm.com
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`2
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`Case 2:12-md-02311-SFC-RSW ECF No. 2123, PageID.38532 Filed 03/09/21 Page 3 of 4
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`Aaron M. Panner
`Matthew R. Huppert
`Daniel S. Severson
`KELLOGG, HANSEN, TODD,
` FIGEL & FREDERICK, P.L.L.C.
`1615 M Street, N.W., Suite 400
`Washington, D.C. 20036
`(202) 326-7900
`apanner@kellogghansen.com
`mhuppert@kellogghansen.com
`dseverson@kellogghansen.com
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`Counsel for Financial Recovery
`Services, LLC
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`3
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`Case 2:12-md-02311-SFC-RSW ECF No. 2123, PageID.38533 Filed 03/09/21 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on March 9, 2021, I electronically filed the foregoing
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`document with the Clerk of the Court using the ECF system, which will send
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`notification of such filing to counsel of record.
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` /s/ Laura S. Faussié
` Laura S. Faussié
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