Bryan Pringle v. William Adams Jr et al
Filing
242
Amendment to MOTION for Sanctions Rule 11 237 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Miller, Donald)
1 DONALD A. MILLER (SBN 228753)
dmiller@loeb.com
2 BARRY I. SLOTNICK (Pro Hac Vice)
bslotnick@loeb.com
3 TAL E. DICKSTEIN (Pro Hac Vice)
tdickstein@loeb.com
4 LOEB & LOEB LLP
10100 Santa Monica Boulevard, Suite 2200
5 Los Angeles, California 90067-4120
Telephone: 310-282-2000
6 Facsimile: 310-282-2200
7 Attorneys for SHAPIRO, BERNSTEIN
& CO., INC., FREDERIC
8 RIESTERER, and DAVID GUETTA
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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SOUTHERN DIVISION
13 BRYAN PRINGLE, an individual,
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Plaintiff,
v.
16 WILLIAM ADAMS, JR.; STACY
FERGUSON; ALLAN PINEDA; and
17 JAIME GOMEZ, all individually and
collectively as the music group The
18 Black Eyed Peas, et al.,
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Defendants.
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Case No. SACV 10-1656 JST(RZx)
Hon. Josephine Staton Tucker
Courtroom 10A
AMENDED NOTICE OF MOTION
BY DEFENDANTS SHAPIRO
BERNSTEIN & CO., INC.,
FREDERIC RIESTERER AND
DAVID GUETTA FOR SANCTIONS
AGAINST PLAINTIFF AND HIS
COUNSEL PURSUANT TO FED. R.
CIV. P. 11
Complaint Filed: October 28, 2010
Trial Date: May 8, 2012
Motion Hearing Date: April 16, 2012
Motion Hearing Time: 10:00 AM
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NY1000367.3
217131-10001
NOTICE OF MOTION FOR SANCTIONS
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PLEASE TAKE NOTICE that, on April 16, 2012 at 10:00 AM or as soon
2 thereafter as counsel may be heard in the courtroom of the Honorable Josephine
3 Staton Tucker, United States District Judge, Central District of California, located at
4 the Santa Ana Courthouse, 411 West Fourth Street, Courtroom 10A, Santa Ana,
5 California 92701-4516, Defendants Shapiro, Bernstein & Co, Inc., Frederic
6 Riesterer and David Guetta (collectively “Defendants”), will and hereby do move
7 for an Order imposing sanctions on Plaintiff Bryan Pringle and his present and
8 former counsel—Dean A. Dickie and Kathleen E. Koppenhoefer, individually as
9 well as jointly and severally with Miller, Canfield, Paddock & Stone, P.L.C.; Ira P.
10 Gould and Ryan L. Greely, individually as well as jointly and severally with Gould
11 Law Group; and George L. Hampton IV and Colin C. Holley, individually as well
12 as jointly and severally with HamptonHolley LLP.
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This Motion is made pursuant to Rule 11 of the Federal Rules of Civil
14 Procedure, the Local Rules of this Court, and is based on this Notice of Motion;
15 Defendants’ Memorandum of Law in Support of Motion for Sanctions Against
16 Plaintiff and His Counsel Pursuant to Fed. R. Civ. P. 11; the Declaration of Tal E.
17 Dickstein with exhibits thereto; the Court file; any reply Defendants may make; and
18 any further papers or argument as may be presented to the Court prior to or at the
19 hearing on this motion, or subsequent thereto as directed by the Court.
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Pursuant to Fed. R. Civ. P. 11(c)(2), this motion and supporting documents
21 were served on Plaintiff’s counsel and all counsel of record on February 6, 2012,
22 more than 21 days prior to the filing of this motion.
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This motion is made following Defendants’ participation in a conference of
24 counsel pursuant to Local Rule 7-3 held on June 27, 2011, as well as Defendants’
25 invitation to hold an additional conference of counsel following service of this
26 motion, which invitation was declined by Plaintiff’s counsel.
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NY1000367.3
217131-10001
1
NOTICE OF MOTION FOR SANCTIONS
1 Dated: March 2, 2012
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By: s/ Tal E. Dickstein
Donald A. Miller
Barry I. Slotnick
Tal E. Dickstein
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LOEB & LOEB LLP
NY1000367.3
Attorneys for Defendants
SHAPIRO, BERNSTEIN & CO., INC.,
FREDERIC RIESTERER and DAVID
GUETTA
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NY1000367.3
217131-10001
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NOTICE OF MOTION FOR SANCTIONS
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