Strojnik v. Costar Realty Information, Inc. et al

Filing 124

Strojnik v. Costar Realty Information, Inc. et al

Doc. 12

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E. SCOTT DOSEK #012114 JOHN P. PASSARELLI #16018 (NE) KUTAK ROCK LLP Suite 300 8601 North Scottsdale Road Scottsdale, AZ 85253-2742 [phone] Facsimile: [phone] Attorneys for Plaintiff / Counterdefendant / Counterclaimant Soilworks, LLC UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA SOILWORKS, LLC, an Arizona corporation, Plaintiff / Counterdefendant / Counterclaimant, v. MIDWEST INDUSTRIAL SUPPLY, INC., an Ohio corporation authorized to do business in Arizona, Defendant / Counterclaimant / Counterdefendant.

NO.: 2:06-CV-2141-DGC SOILWORKS, LLC'S RESPONSE TO MIDWEST INDUSTRIAL SUPPLY, INC.'S MOTION IN LIMINE (DOC. #105) TO BAR EVIDENCE REGARDING ANY LEGAL ADVICE SOILWORKS, LLC MAY HAVE RECEIVED CONCERNING MIDWEST'S PATENTS (Before the Honorable David G. Campbell)

In response to Midwest's Motion in Limine with respect to legal advice Soilworks, LLC may have received regarding Midwest's patents ("Motion"), Soilworks gave full and complete answers to the written discovery propounded upon it by Midwest during the discovery process. Soilworks has never claimed that it relied on advice of counsel, or that any documents exist regarding such advice with respect to Midwest's patents. For the foregoing reasons, Soilworks, LLC respectfully requests that the Court deny Midwest's Motion in Limine to Bar Evidence Regarding Any Legal Advice Soilworks, LLC May Have Received Concerning Midwest's Patents.

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4821-8584-2179.1

Dockets.Justia.com

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Dated this 24th day of September, 2008. KUTAK ROCK LLP By /s E. Scott Dosek E. Scott Dosek, Esq. John P. Passarelli, Esq. 8601 North Scottsdale Road #300 Scottsdale, AZ 85253-2742 Attorneys for Plaintiff Soilworks, LLC

4821-8584-2179.1

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4821-8584-2179.1

CERTIFICATE OF SERVICE I hereby certify that on September 24, 2008, the foregoing SOILWORKS, LLC'S RESPONSE TO MIDWEST'S MOTION IN LIMINE TO BAR EVIDENCE REGARDING ANY LEGAL ADVICE SOILWORKS, LLC MAY HAVE RECEIVED CONCERNING MIDWEST'S PATENTS was filed electronically. Notice of this filing will be sent to all parties by operations of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s Amy S. Fletcher Amy S. Fletcher

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