Blaszkowski et al v. Mars Inc. et al

Filing 428

MOTION to Compel the Depositions of Plaintiffs and Incorporated Memorandum of Law by Mars Petcare US, Inc., Mars Inc.. Responses due by 8/7/2008 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Ortega, Omar)

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Blaszkowski et al v. Mars Inc. et al Doc. 428 Att. 6 EXHIBIT F Dockets.Justia.com Page 1 of 2 Kristen Caverly From: Sent: To: Cc: Catherine J. MacIvor [CMacIvor@mflegal.com] Thursday, May 01, 2008 11:16 AM Kristen Caverly Bjorg Eikeland; Russell Keith Subject: RE: Depositions Krist i n, This shall confirm that these notices were provided to me after I had already advised you of extensive conflicts that I have with these dates and without first waiting for me to check with the Plaintiffs as to their availability and travel issues, particularly where many of them must care for cats and/or dogs which are very ill. As discussed, notwithstanding the fact that I am on vacation, I am attempting to ascertain their individual availability and will discuss same with you next week. I would also like you to discuss with your clients when a corporate representative will be available for each and every manufacturer defendant on the topics that will be the same or similar to our requests for production, commencing with the advertising. In order to meet trial schedules and the schedule for the class certification motion, we will need to conduct these at the same time. I would appreciate dates as soon as possible. Thank you. Cathy From: Kristen Caverly [mailto:kcaverly@hcesq.com] Sent: Monday, April 28, 2008 5:21 PM To: Catherine J. MacIvor Cc: ABrown@ssd.com; acraig@carltonfields.com; ADavis@wc.com; adober@akingump.com; agoodwin@ssd.com; agreer@richmangreer.com; alan.fry@akerman.com; alexander.shaknes@dlapiper.com; BLitten@ssd.com; breid@carltonfields.com; bwright@ficlaw.com; cahoover@hhlaw.com; CALicko@HHLAW.com; ckalil@aballi.com; cristen.rose@dlapiper.com; csalup@patinolaw.com; dbutswinkas@wc.com; djireland@ficlaw.com; dlagrua@cozen.com; dtamarazzo@patinolaw.com; ecarrigan@akingump.com; edhogan@hhlaw.com; frothrock@shb.com; hugh.turner@akerman.com; jarden@sidley.com; jbmurray@ssd.com; jerry.trippitelli@dlapiper.com; jkuster@sidley.com; JLund@wc.com; jmcdonough@cozen.com; jmullen@cozen.com; jnegovan@cozen.com; jpoyer@aballi.com; jrenzi@ssd.com; JReuss@lanealton.com; jweinstein@ssd.com; jyork@mcguirewoods.com; kmccall@sidley.com; Laura.L.Daly@supervalu.com; lchasteen@ficlaw.com; lonnie.simpson@dlapiper.com; lsanom@ficlaw.com; mary.gately@dlapiper.com; mek@kubickidraper.com; mgoodman@ssd.com; mlberge@hhlaw.com; morton.ws@pg.com; MWaller@lanealton.com; phoulihan@wc.com; plascala@shb.com; psechler@wc.com; RCTroyer@hhlaw.com; rd@kubickidraper.com; rfama@cozen.com; richard.segal@pillsburylaw.com; RLHanger@ssd.com; rpatino@patinolaw.com; rteslik@akingump.com; rwheeler@cozen.com; scolombo@cozen.com; thentoff@wc.com; Tony Farmani Subject: Cathy, Thank you for talking with me and Phil last Wednesday. In furtherance of our efforts to schedule plaintiffs' depositions, attached are deposition notices with the dates defendants' propose. We have set them in Miami as we suggested, but we are open to working with you on the dates and locations as we discussed on Wednesday. I realize that you are out of the office and that the depositions will not begin on May 12 as noticed, so I will not expect a response until you provide us with your proposed schedule on May 6. 7/21/2008 Page 2 of 2 Kristen Kristen E. Caverly, Partner Henderson & Caverly LLP 16236 San Dieguito Road, Suite 4-13 P.O. Box 9144 (all US Mail) Rancho Santa Fe, CA 92067-9144 858-756-6342 x)101 858-756-4732 fax This e-mail message contains information from the law firm of Henderson & Caverly LLP which may be confidential and privileged. The information is intended for the sole use of the individual or entity named in the address box. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. 7/21/2008

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