Massoli v. Regan Media, et al

Filing 86

Massoli v. Regan Media, et al

Doc. 86

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LAW OFFICES

James L. Blair, #016125 Roger W. Hall, #013727 RENAUD COOK DRURY MESAROS, PA Phelps Dodge Tower One North Central, Suite 900 Phoenix, Arizona 85004-4417 [phone] [e-mail] [e-mail] Attorneys for Plaintiff/Counterdefendants UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA JENNA MASSOLI p/k/a JENNA JAMESON, Plaintiff, v. "REGAN MEDIA," JUDITH REGAN, as an individual, Defendant. REGAN MEDIA, INC., a New York corporation, and JUDITH REGAN, an individual, Defendants/Counterclaimants, v. JENNA MASSOLI, p/k/a JENNA JAMESON, an individual, Plaintiff/Counterdefendant, and JAY GRDINA, an individual, Third-Party Counterdefendant, and DOLCE AMORE, INC., a Colorado corporation, Counterdefendant. CV 05-0854 PHX EHC ATTORNEY'S CERTIFICATE OF COMPLIANCE WITH LRCiv 83.3(b)(2)(A)

(Assigned to the Honorable Earl H. Carroll)

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

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Dockets.Justia.com

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LAW OFFICES

Pursuant to LRCiv 83.3(b)(2)(A), Rules of Practice of the United States District Court for the District of Arizona, attorney Roger W. Hall of the firm of Renaud Cook Drury Mesaros, PA ("RCDM" or the "firm") hereby certifies that on June 24, 2005, attorney Gary Crandell, Esq., of Denver, Colorado, longtime transactional counsel for plaintiff/counterdefendants Jenna Massoli p/k/a Jenna Jameson, Jay Grdina, and Dolce Amore, Inc. was notified, by an e-mail from the undersigned, of this Court's June 20 pretrial order. A copy of the pretrial order was attached to that e-mail. On November 28, 2005, Counterdefendant Jay Grdina, husband of plaintiff Jenna Massoli and one of two sole shareholders of Dolce Amore, Inc. (along with Massoli), was notified, by e-mail from the undersigned, of the pretrial order. A copy of the pretrial order was attached to Mr. Grdina's e-mail. On February 15, 2006, the undersigned e-mailed Mr. Grdina and attorney Crandell a copy of a letter the undersigned had received from opposing counsel. Opposing counsel advised that another motion to compel, as well as a motion for sanctions would be forthcoming unless the responses to their Request for Production of Documents was supplemented to be responsive. Again, the undersigned requested contact from Mr. Grdina. On February 20, 2006, the undersigned e-mailed attorney Gary Crandell, Esq., of Denver, Colorado, Massoli and Grdina's longtime transactional counsel, with copies of Defendants/Counterclaimants' most recent filings in this matter, i.e., the Second Motion to Compel and Request for Sanctions, etc. On February 21, 2006, copies were sent to Mr. Grdina as well. On March 1, 2006, attorney Jim Blair of this office sent a letter to Mr. Grdina, Ms. Jameson, and attorney Crandell, via e-mail and U.S. mail, setting forth certain requirements that would need to be complied with on or before March 3, 2006, and advising that if those requirements were not met, that the firm would be forced to withdraw from representation.

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

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LAW OFFICES

Neither Mr. Grdina, Ms. Jameson, nor Mr. Crandell responded to that letter, either by reply e-mail, or by telephone. On March 7, 2006, Mr. Grdina and attorney Crandell were reminded, via e-mail, of the pending response deadline regarding Defendants/Counterclaimants' Second Motion to Compel and Motion for Sanctions, etc. On that same date, Mr. Grdina was also furnished with additional copies of those papers. On March 7, 2006, the undersigned advised opposing counsel that RCDM would be withdrawing from its representation of Plaintiff/Counterdefendants and sought an extension of time for RCDM's clients to file a response to the Second Motion to Compel and Motion for Sanctions. Opposing counsel refused to grant an extension, and Mr. Grdina and attorney Crandell were advised of that fact. Mr. Grdina has been fully apprised of all pending dates and deadlines in this matter. RESPECTFULLY SUBMITTED this 7th day of March, 2006. RENAUD COOK DRURY MESAROS, PA

By: /s/ Roger W. Hall James L. Blair Roger W. Hall Phelps Dodge Tower One North Central, Suite 900 Phoenix, AZ 85004-4417 Attorneys for Plaintiff/Counterdefendants

Filed electronically this 7th day of March, 2006. COPY of the foregoing hand-delivered to the Honorable Earl H. Carroll the 8th day of March, 2006. /// ///

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

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LAW OFFICES

COPY of the foregoing mailed this 7th day of March, 2006, to: Jeffrey F. Reina, Esq. LIPSITZ, GREEN, FAHRINGER, ROLL, SALISBURY & CAMBRIA LLP 42 Delaware Avenue, Suite 300 Buffalo, NY 14202-3857 Co-counsel for Plaintiff/Counterdefendants David J. Bodney, Esq. Dennis K. Blackhurst, Esq. STEPTOE & JOHNSON, LLP Collier Center 201 East Washington Street, Ste 1600 Phoenix, AZ 85004-2382 Attorneys for Defendants/Counterclaimants Ms. Jenna Massoli 16444 North 91st Street, Suite 100 Scottsdale, Arizona 85260 Mr. Jay Grdina 16444 North 91st Street, Suite 100 Scottsdale, Arizona 85260 Dolce Amore, Inc. c/o Mr. Jay Grdina 16444 North 91st Street, Suite 100 Scottsdale, Arizona 85260 Dolce Amore, Inc. 15720 N. 83rd Place Scottsdale, Arizona 85260

/s/ Deborah Robertson
@PFDesktop\::ODMA/MHODMA/IMANAGE;RCD_PHX;319559;1

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

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