Silvers v. Google, Inc.

Filing 274

MOTION for Hearing on Plaintiff's Motion to Compel Defendant Google, Inc.'s Production of Its Principals for Deposition by Stelor Productions, LLC. (Swing, Morgan)

Silvers v. Google, Inc.

Doc. 274

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 05-80387 CIV RYSKAMP/VITUNAC STEVEN A. SILVERS, an individual, Plaintiff, v. GOOGLE INC., a Delaware corporation, Defendant. _______________________________________/ GOOGLE INC., a Delaware corporation, Counterclaimant, v. STEVEN A. SILVERS, an individual; STELOR PRODUCTIONS, INC., a Delaware Corporation; STELOR PRODUCTIONS, LLC, a Delaware limited liability company, and STEVEN ESRIG, an individual, Counterdefendants. ________________________________________/ PLAINTIFF STELOR'S REQUEST FOR HEARING ON PLAINTIFF'S MOTION TO COMPEL DEFENDANT GOOGLE'S PRODUCTION OF ITS PRINCIPALS FOR DEPOSITION Pursuant to Local Rule 7.1(B)(1), Plaintiff Stelor Productions, LLC f/k/a Stelor Productions, Inc., by and through undersigned counsel, respectfully requests a hearing regarding Plaintiff's Motion to Compel Depositions of Defendant Google, Inc.'s Principals ("Motion"), as filed with this Court on June 23, 2008. Defendants believe oral argument will assist the Court in a full understanding of the considerable facts and legal arguments set forth by both Plaintiffs and

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Defendants with respect to this Motion. Plaintiff estimates that a total of 30 minutes is required for oral argument. Accordingly, Plaintiff respectfully requests that a 30 minute hearing be held on the Motion. Respectfully submitted, s/Kevin C. Kaplan - Florida Bar No. 933848 David J. Zack - Florida Bar No. 641685 Morgan L. Swing ­ Florida Bar No. 17092 Email: [e-mail] [e-mail] [e-mail] COFFEY BURLINGTON Office in the Grove, Penthouse A 2699 South Bayshore Drive Miami, Florida 33133 Tel: [phone] Fax: [phone] Counsel for STELOR PRODUCTIONS, LLC and STEVEN ESRIG

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CERTIFICATE OF SERVICE I hereby certify that on August 1, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the Mailing Information for Case 9:05-cv-80387KLR. I also certify that the foregoing Counsel of record currently identified on the Mailing Information list to receive e-mail notices for this case are served via Notices of Electronic Filing generated by CM/ECF. Counsel of record who are not on the Mailing Information list to receive e-mail notices for this case have been served via U.S. Mail.

/s/ Morgan L. Swing

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