Asia Economic Institute et al v. Xcentric Ventures LLC et al

Filing 87

EX PARTE APPLICATION to Continue the determination of, or denying, Defendants' Motion for Summary Judgment from July 12, 2010 to At the Court's discretion Re: MOTION for Summary Judgment as to Entire Case 40 , EX PARTE APPLICATION to Enforce Order to Compel Continued Deposition of Defendant Edward Magedson, EX PARTE APPLICATION for Sanctions Local Rule 83.7, Local Rule 37-4, and this Court's inherent authority filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 1 to Declaration of Lisa J. Borodkin, # 2 Exhibit 2 to Declaration of Lisa J. Borodkin, # 3 Exhibit 3 to Declaration of Lisa J. Borodkin, # 4 Exhibit 4 to Declaration of Lisa J. Borodkin, # 5 Exhibit 5 to Declaration of Lisa J. Borodkin, # 6 Exhibit 6 to Declaration of Lisa J. Borodkin, # 7 Exhibit 7 to Declaration of Lisa J. Borodkin, # 8 Exhibit 8 to Declaration of Lisa J. Borodkin, # 9 Exhibit 9 to Declaration of Lisa J. Borodkin, # 10 Exhibit 10 to Declaration of Lisa J. Borodkin, # 11 Exhibit 11 to Declaration of Lisa J. Borodkin, # 12 Exhibit 12 to Declaration of Lisa J. Borodkin, # 13 Exhibit 13 to Declaration of Lisa J. Borodkin, # 14 Exhibit 14 to Declaration of Lisa J. Borodkin, # 15 Exhibit 15 to Declaration of Lisa J. Borodkin, # 16 Exhibit 16 to Declaration of Lisa J. Borodkin, # 17 Exhibit 17 to Declaration of Lisa J. Borodkin, # 18 Exhibit 18 to Declaration of Lisa J. Borodkin, # 19 Exhibit 19 to Declaration of Lisa J. Borodkin, # 20 Exhibit 20 to Declaration of Lisa J. Borodkin, # 21 Exhibit 21 to Declaration of Lisa J. Borodkin, # 22 Exhibit 22 to Declaration of Lisa J. Borodkin, # 23 Exhibit 23 to Declaration of Lisa J. Borodkin, # 24 Exhibit 24 to Declaration of Lisa J. Borodkin, # 25 Exhibit 25 to Declaration of Lisa J. Borodkin, # 26 Exhibit 26 to Declaration of Lisa J. Borodkin, # 27 Exhibit 27 to Declaration of Lisa J. Borodkin, # 28 Exhibit 28 to Declaration of Lisa J. Borodkin, # 29 Exhibit 29 to Declaration of Lisa J. Borodkin, # 30 Exhibit 30 to Declaration of Lisa J. Borodkin, # 31 Exhibit 31 to Declaration of Lisa J. Borodkin, # 32 Exhibit 32 to Declaration of Lisa J. Borodkin, # 33 Exhibit 33 to Declaration of Lisa J. Borodkin, # 34 Exhibit 34 to Declaration of Lisa J. Borodkin, # 35 Exhibit 35 to Declaration of Lisa J. Borodkin, # 36 Exhibit 36 to Declaration of Lisa J. Borodkin, # 37 Exhibit 37 to Declaration of Lisa J. Borodkin)(Borodkin, Lisa)

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Gmaila Economic Institute et al v. Xcentric Ventures LLC et al Asi - Meet and confer https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&Att.peth... Doc. 87 q=s 37 Lisa Borodkin <lborodkin@gmail.com> Meet and confer Lisa Borodkin <lborodkin@gmail.com> Wed, Jul 7, 2010 at 3:24 PM To: "<david@ripoffreport.com>" <david@ripoffreport.com>, Maria Crimi Speth <mcs@jaburgwilk.com> Cc: Daniel Blackert <blackertesq@yahoo.com>, "paul@berra.org" <paulsberra@gmail.com> David and Maria, I left messages for both of you returning your call today, which I understand was to seek extensions to the deadlines for submitting various pre-trial filings. Also, we plan to move ex parte for a continuance of Defendants' motion for summary judgment. The grounds are to conduct discovery, in particular to continue the deposition of Defendant Ed Magedson, as ordered by Magistrate Walsh on June 24, 2010. The specific discovery needed is set forth in detail in my email to the Court of last Friday, July 2, 2010. We may also seek sanctions. Please contact me immediately if we can resolve this without an ex parte application. Lisa [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] On Mon, Jun 28, 2010 at 2:22 PM, David Gingras < <mailto:david@ripoffreport.com> <mailto:david@ripoffreport.com> <mailto:david@ripoffreport.com> <mailto:david@ripoffreport.com> david@ripoffreport.com> wrote: I don't understand -- what do you mean about meeting and conferring re: Rule 26(f)? Did you mean 56(f)? 1 of 3 Dockets.Justia.com 7/8/2010 7:05 PM Gmail - Meet and confer https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Lisa Borodkin <lborodkin@gmail.com> Meet and confer Maria Crimi Speth <mcs@jaburgwilk.com> Wed, Jul 7, 2010 at 3:57 PM To: Lisa Borodkin <lborodkin@gmail.com>, david@ripoffreport.com Cc: Daniel Blackert <blackertesq@yahoo.com>, "paul@berra.org" <paulsberra@gmail.com> First, neither your voice message nor your email responded to our inquiry regarding moving the July 12th deadlines one week. What is your position on that? With respect to an ex parte motion, this appears to relate to the same issues that we talked about more than a week ago when you asked about a Rule 56(f) motion. We also talked about this last week when you asked to meet and confer about the additional deposition of Ed Magedson. Our position remains the same -- under Rule 56(f), you are required to identify the discovery that you want and you are required to explain why that discovery is relevant to the pending motion. Based on our discussions, we do not understand how any of the requested discovery relates to or would affect anything in our motion. For example, you indicated that you needed to know the number of people in the CAP program as part of your proof of a pattern. Yet, our summary judgment motion does not argue that there is a lack of a pattern. As such, evidence on this issue is entirely irrelevant and immaterial to our motion. Because you are required to meet and confer with us in good faith before bringing your motion, we would like to renew our request that you explain to us in writing what discovery you need and why it is relevant to the summary judgment motion. To the extent you intend to seek ex parte relief, defendants oppose your motion, expect that you will provide proper notice, and intend to appear in person at any hearing. Maria Crimi Speth, Esq. Jaburg & Wilk, P.C. 3200 N. Central Ave., Suite 2000 Phoenix, AZ 85012 602-248-1089 602-248-0522 (fax) www.jaburgwilk.com This communication is intended only for the individual or entity to whom it is directed. It may contain information that is privileged, confidential, or otherwise exempt from disclosure under applicable law. Dissemination, distribution, or copying of this communication by anyone other than the intended recipient, or a duly designated employee or agent of such recipient, is prohibited. If you have received this communication in error, please notify us immediately by telephone at (602) 248-1000, or via e-mail, and delete this message and all attachments thereto. From: Lisa Borodkin [mailto:lborodkin@gmail.com] Sent: Wednesday, July 07, 2010 3:24 PM To: <david@ripoffreport.com>; Maria Crimi Speth Cc: Daniel Blackert; paul@berra.org Subject: Re: Meet and confer David and Maria, I left messages for both of you returning your call today, which I understand was to seek extensions to the deadlines for submitting various pre-trial filings. 1 of 21 7/8/2010 7:04 PM Gmail - Meet and confer https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Lisa Borodkin <lborodkin@gmail.com> Meet and confer Lisa Borodkin <lborodkin@gmail.com> Wed, Jul 7, 2010 at 4:08 PM To: Maria Crimi Speth <mcs@jaburgwilk.com> Cc: david@ripoffreport.com, Daniel Blackert <blackertesq@yahoo.com>, "paul@berra.org" <paulsberra@gmail.com> We are moving for sanctions. Pursuant to Local Rule 7-19 it is my duty to advise you that we intend to file the ex parte application today or tomorrow for submission July 9, 2010. Thank you for your position on opposition and request to be present. Although Judge Wilson does not hear ex parte applications, I believe you are entitled to notice and a hearing on the request for sanctions. We will request a hearing date for that in our application. [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> http://www.ripoffreport.com/ <mailto:David@RipoffReport.com> <mailto:David@RipoffReport.com> <mailto:David@RipoffReport.com> David@RipoffReport.com <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> <http://www.ripoffreport.com/> http://www.ripoffreport.com/ 1 of 2 7/8/2010 7:04 PM

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