free trade, unilateral and economic trade sanctions

 

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

 
NATIONAL FOREIGN TRADE COUNCIL,

      Plaintiff,

- v.-

CHARLES D. BAKER, in his official capacity as Secretary of Administration and Finance of the Commonwealth of Massachusetts, and PHILMORE ANDERSON, III, in his official capacity as State Purchasing Agent for the Commonwealth of Massachusetts,

      Defendants.
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 Civil Action No. ______


MOTION FOR LEAVE TO EXCEED PAGE LIMIT

Plaintiff, the National Foreign Trade Council, hereby moves this Court, pursuant to LR 7.1(B)(4), for leave to file a Memorandum of Points and Authorities exceeding 20 pages (submitted herewith) in support of its Motion for Preliminary Injunction or in the Alternative for Consolidation and Expedited Consideration of the Merits. The additional pages are required in order to permit Plaintiff adequately to describe the Massachusetts statute and its operation and to address the complex constitutional questions raised by the motion.

Plaintiff's counsel certifies, pursuant to Local Rule 7.1(A), that it has conferred with defendants' counsel and has attempted in good faith to resolve or narrow the issues presented by this motion. Counsel for defendants, Thomas A. Barnico, has authorized us to state they consent to this motion.


Dated: April 30, 1998

                Respectfully submitted,


                /s/ Michael A. Collora
                Michael A. Collora
                Dwyer & Collora
                Federal Reserve Plaza
                600 Atlantic Avenue
                Boston, MA 02210-2211
                (617) 371-1000


                /s/ Timothy B. Dyk
                Timothy B. Dyk
                Robert H. Klonoff
                Gregory A. Castanias
                Melissa Hart*
                JONES, DAY, REAVIS & POGUE
                1450 G Street, N.W.
                Washington, D.C. 20005-2088
                (202) 879-3939

                Attorneys for Plaintiff
                National Foreign Trade Council


* Admitted in Maryland; not admitted in the District of Columbia

 

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