Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 143

APPENDIX to 134 MOTION for Partial Summary Judgment Against Heartland for Unfair Competition, 142 Response to Motion, 141 Cross MOTION for Summary Judgment /Appendix in Support of Heartland's Response to Forest River's Motion for Partial Summary Judgment and its Cross-Motion for Summary Judgment by Heartland Recreational Vehicles LLC. (Attachments: # 1 Supplement I. Heartland's Statement of Genuine Disputes and Material Facts, # 2 Exhibit Ex. A - Babcock depo excerpts, # 3 Exhibit Ex. B - Lung declaration, # 4 Exhibit Ex. C - Printout of Open Range RV website, # 5 Exhibit Ex. D - Printout of Keystone RV website, # 6 Exhibit Ex. E - Lung affidavit, # 7 Exhibit Ex. F - Leonard depo excerpts, # 8 Exhibit Ex. G - Hoffman depo excerpts, # 9 Exhibit Ex. H - Campkin affidavit, # 10 Exhibit Ex. I - Plummer depo excerpts, # 11 Exhibit Ex. J - Donat affidavit, # 12 Exhibit Ex. K - Forest River's Answers to Heartland's Second Set of Interrogatories, # 13 Exhibit Ex. L - 310-CV-409 complaint, # 14 Exhibit Ex. M - Indiana Model Civil Jury Instructions, 2010 ed.)(Irmscher, David)

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Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 143 UNITED STATES DISTRICT COURT Northern District of Indiana South Bend Division HEARTLAND RECREATIONAL VEHICLES, LLC, Plaintiff, v. FOREST RIVER, INC., Defendant. ) ) ) ) ) ) ) ) ) CASE NO.: 3:08-cv-490 JD APPENDIX IN SUPPORT OF HEARTLAND'S RESPONSE TO FOREST RIVER'S MOTION FOR PARTIAL SUMMARY JUDGMENT AND ITS CROSS-MOTION FOR SUMMARY JUDGMENT Pursuant to N.D. Ind. L.R. 56.1 and Fed. R. Civ. P. 56, Heartland Recreational Vehicles, LLC ("Heartland"), submits the following Appendix in Support of its Response to Forest River's Motion for Partial Summary Judgment and Heartland's Cross-Motion for Summary Judgment. The Appendix includes Heartland's Statement of Genuine Disputes and Material Facts. I. II. EXH. A. B. C. D. E. F. G. H. HEARTLAND'S STATEMENT OF GENUINE DISPUTES AND MATERIAL FACTS APPENDIX OF EXHIBITS DESCRIPTION Excerpts from Deposition of Jeffrey Babcock, Forest River's 30(b)(6) Designee Declaration of Rod Lung Submitted by Forest River Printout of Open Range RV website Printout of Keystone RV website Affidavit of Rod Lung Excerpts from Deposition of John Leonard Excerpts from Deposition of Timothy Hoffman Affidavit of Brad Campkin BDDB01 6448347v1 Dockets.Justia.com I. J. K. L. M. Excerpts from Deposition of Jack Plummer Affidavit of Dennis Donat Forest River's Answers to Heartland's Second Set of Interrogatories Complaint filed by Forest River, Inc. in Cause No. 3:10-CV-409 JD INDIANA MODEL CIVIL JURY INSTRUCTIONS, 2010 Edition, 3123-3135 BAKER & DANIELS LLP By: /s/ David P. Irmscher David P. Irmscher (#15026-02) Abigail M. Butler (#22295-02) Peter A. Meyer (#27968-53) 111 East Wayne, Suite 800 Fort Wayne, Indiana 46802 Tel: 260.424.8000 Fax: 260.460.1700 david.irmscher@bakerd.com abigail.butler@bakerd.com peter.meyer@bakerd.com ATTORNEYS FOR PLAINTIFF, HEARTLAND RECREATIONAL VEHICLES, LLC -2BDDB01 6448347v1 CERTIFICATE OF SERVICE The undersigned counsel for plaintiff Heartland Recreational Vehicles, LLC, hereby certifies that a copy of the foregoing was served upon the following, this 8th day of December, 2010, by operation of the Court's electronic filing system: Ryan M. Fountain 420 Lincoln Way West Mishawaka, Indiana 46544-1902 /s/ David P. Irmscher David P. Irmscher -3BDDB01 6448347v1