Toffoloni v. LFP Publishing Group, LLC

Filing 101

Emergency MOTION to Compel Discovery Response with Brief In Support by Maureen Toffoloni. (Attachments: # 1 Brief in Support of Motion)(Decker, Richard)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA MAUREEN TOFFOLONI, as Administrarix and Personal Representative of the ESTATE OF NANCY E. BENOIT, Plaintiff, v. LFP PUBLISHING GROUP, LLC, d/b/a Hustler Magazine, MARK SAMANSKY, an Individual, and other distributors and sellers of, Hustler Magazine, as Defendants X, Y, and Z, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION FILE NO. 1:08-CV-0421-TWT

PLAINTIFF'S EMERGENCY MOTION TO COMPEL DISCOVERY RESPONSE COMES NOW, Plaintiff, Maureen Toffoloni, and pursuant to Local Rules 7.2B and 37.1, Federal Rule of Civil Procedure 37, and for good cause shown, submits this Emergency Motion to Compel Discovery Response from Defendant LFP Publishing Group, LLC concerning Plaintiff's Second Continuing Interrogatories and Request for Production of Documents filed on December 21, 2009. In support of her Motion, Plaintiff relies upon her Brief in Support of Plaintiff's Emergency Motion to
3197-007\\Pleading\33735.wpd

Comp el

Discovery

Response

and

accompanying

exhibits,

submitted

contemporaneously herewith. Respectfully submitted March 11, 2010. /s/ Richard P. Decker RICHARD P. DECKER State Bar of Georgia #215600 [e-mail] F. EDWIN HALLMAN, JR. State Bar of Georgia #319800 [e-mail] RICHARD A. WINGATE State Bar of Georgia #770617 [e-mail] ZACHARY M. WILSON III State Bar of Georgia #559581 [e-mail] For HALLMAN & WINGATE, LLC Attorneys for Plaintiff 166 Anderson Street, S.E. Suite 210 Marietta, Georgia 30060 [phone]

3197-007\\Pleading\33735.wpd

-2-