Massoli v. Regan Media, et al

Filing 59

Massoli v. Regan Media, et al

Doc. 59

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STEPTOE & JOHNSON LLP Collier Center 201 East Washington Street, Suite 1600 Phoenix, Arizona 85004-2382 Telephone: [phone] Facsimile: [phone] David J. Bodney (006065) Dennis K. Blackhurst (021678) Attorneys for Defendants/Counterclaimants Regan Media, Inc. and Judith Regan UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA JENNA MASSOLI p/k/a JENNA JAMESON, Plaintiff, vs. " EGAN MEDIA," JUDITH R and REGAN, an individual, Defendants. REGAN MEDIA, INC., a New York corporation, and JUDITH REGAN, an individual, Defendants/Counterclaimants, vs. JENNA MASSOLI p/k/a JENNA JAMESON, an individual, Plaintiff/Counterdefendant, and JAY GRDINA, an individual, and DOLCE AMORE, INC., a Colorado corporation, Counterdefendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV 05-0854 PHX EHC RULE 30(B)(6) NOTICE OF DEPOSITION OF DOLCE AMORE, INC.

(Assigned to the Honorable Earl H. Carroll)

Case 2:05-cv-00854-EHC

Document 59

Filed 11/04/2005

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Dockets.Justia.com

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YOU ARE HEREBY NOTIFIED that, pursuant to Federal Rules of Civil Procedure 26 and 30(b)(6), Dolce Amore, Inc (" olce Amore" is required to designate D ) one or more of the most knowledgeable officers, directors, or managing agents, or other persons who consent to testify on Dolce Amore'behalf, to appear and to testify as to the s matters known or reasonably available to Dolce Amore with respect to designated subjects on which examination is requested. The matters on which examination is requested

pursuant to Rule 30(b)(6) are the factual bases of the claims and defenses asserted by Dolce Amore in this action, including without limitation, the following matters: 1. Amore; 2. Amounts received by Dolce Amore from the A&E Television Networks Facts relating to the corporate ownership, structure and governance of Dolce

(" &E" under the January 2005 Television Reality Series/Project Production Agreement A ) (the " &E Contract" between Dolce Amore and A&E; A ) 3. Contract; 4. Facts relating to Dolce Amore' efforts to market or promote a potential s Facts relating to the terms, drafting, negotiation and execution of the A&E

reality-based television program featuring Jenna Massoli p/k/a Jenna Jameson ("ameson" J ); 5. Facts relating to the terms, drafting, negotiation and execution of the

Exclusive Acting Services Agreement between Jameson and Dolce Amore as referenced in the A&E Contract; 6. Facts relating to the terms, drafting, negotiation and execution of the Artist' s

Letter of Inducement executed by Jameson and attached to the A&E Contract; 7. Facts relating to Dolce Amore' responses to Defendants/Counterclaimants' s

First Set of Interrogatories and First Set of Requests for Production; and

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8.

Facts relating to amounts paid by Dolce Amore to Jameson, Jay Grdina or

any other person or entity from October 2003 to the present. DATE AND TIME OF DEPOSITION: PLACE OF APPEARANCE: January 10, 2006 at 9:00 a.m. STEPTOE & JOHNSON LLP Collier Center 201 East Washington Street, Suite 1600 Phoenix, Arizona 85004-2382

Request for reasonable accommodations for persons with disabilities must be made at least three judicial days in advance of a scheduled court proceeding. DATED this 4th day of November, 2005. STEPTOE & JOHNSON LLP By /s/ David J. Bodney David J. Bodney Dennis K. Blackhurst Collier Center 201 East Washington Street Suite 1600 Phoenix, Arizona 85004-2382 Attorneys for Defendants/ Counterclaimants Regan Media, Inc. and Judith Regan

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CERTIFICATE OF SERVICE I hereby certify that on the 4th day of November, 2005, I caused the attached document to be electronically transmitted to the Clerk'Office using the CM/ECF System s for filing and transmittal of a Notice of Electric Filing to the following CM/ECF Registrants: James L. Blair Roger William Hall Renaud Cook Drury Mesaros, PA Phelps Dodge Tower One North Central, Suite 900 Phoenix, AZ 85004-4417 Attorneys for Plaintiff/Counterdefendant and Third-Party Counterdefendant I hereby certify that on the 4th day of November, 2005, I served the attached document by mail on the following, who are not registered participants of the CM/ECF System: Bernard M. Brodsky Jeffrey F. Reina Lipsitz, Green, Fahringer, Roll, Salisbury & Cambria, LLP 42 Delaware Avenue, Suite 300 Buffalo, NY 14202-3857 Attorneys for Plaintiff/Counterdefendant and Third-Party Counterdefendant

s/Lisa G. Morgan

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