Toffoloni v. LFP Publishing Group, LLC

Filing 73

MOTION for Protective Order Regarding Plaintiff's "Punitive Damages" Discovery with Brief In Support by LFP Publishing Group, LLC. (Attachments: # 1 Brief in Support of Motion for Protective Order, # 2 Exhibit A to Brief in Support of Motion, # 3 Exhibit B to Brief in Support of Motion, # 4 Exhibit C to Brief in Support of Motion, # 5 Exhibit D to Brief in Support of Motion, # 6 Exhibit E to Brief in Support of Motion, # 7 Exhibit F to Brief in Support of Motion, # 8 Exhibit G to Brief in Support of Motion, # 9 Exhibit H to Brief in Support of Motion, # 10 Exhibit I to Brief in Support of Motion, # 11 Exhibit J to Brief in Support of Motion, # 12 Exhibit K to Brief in Support of Motion, # 13 Text of Proposed Order, # 14 Certification of Good Faith Conference)(Bauer, S.)

Toffoloni v. LFP Publishing Group, LLC

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA MAUREEN TOFFOLONI, as Administrator and Personal Representative of the ESTATE OF NANCY E. BENOIT, ) ) ) ) ) Plaintiff, ) ) vs. ) ) LFP PUBLISHING GROUP, LLC, ) d/b/a Hustler Magazine, et al, ) ) Defendant. )

CASE NO. 1:08-cv-00421-TWT

DEFENDANT'S MOTION FOR PROTECTIVE ORDER Pursuant to Federal Rule of Civil Procedure 26(c) and for good cause shown, Defendant LFP Publishing Group, LLC ("LFP") respectfully submits this Motion for Protective Order preventing Plaintiff's First Interrogatories Nos. 7 through 9; Plaintiff's First Request for Production of Documents Nos. 2 through 7; and Plaintiff's Rule 30(b)(6) Notice of Deposition of LFP Topic Nos. 3, 4 and 8 through 11. In support of its Motion, LFP relies upon its Brief in Support of Defendant's Motion for Protective Order with accompanying exhibits, sub mitted contemporaneously herewith.

Dockets.Justia.com

WHEREFORE, LFP respectfully requests that this Court enter a protective order prohibiting Plaintiff's improper, burdensome, and unnecessary "punitive damages" discovery. Respectfully submitted this 7th day of January 2010.

/s/ S. Derek Bauer James C. Rawls Georgia Bar No. 596050 Barry J. Armstrong Georgia Bar No. 022055 S. Derek Bauer Georgia Bar No. 042537 Darrell J. Solomon Georgia Bar No. 305922 McKENNA LONG & ALDRIDGE LLP 303 Peachtree Street, NE, Suite 5300 Atlanta, Georgia 30308 [phone] [phone] (facsimile) Pro hac vice: Paul J. Cambria, Jr. Jeffrey Reina William M. Feigenbaum LIPSITZ GREEN SCIME CAMBRIA LLP 42 Delaware Avenue, Suite 120 Buffalo, NY 14202-3924 [phone] [phone] (facsimile)

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Attorneys for LFP Publishing Group, LLC

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA MAUREEN TOFFOLONI, as Administrator and Personal Representative of the ESTATE OF NANCY E. BENOIT, ) ) ) ) ) Plaintiff, ) ) vs. ) ) LFP PUBLISHING GROUP, LLC, ) d/b/a Hustler Magazine, et al, ) ) Defendant. )

CASE NO. 1:08-cv-00421-TWT

CERTIFICATE OF SERVICE This is to certify that I have this day filed the within and foregoing MOTION FOR PROTECTIVE ORDER via the CM/ECF system which will automatically send notification to Plaintiff's attorneys of record, who are participants in the CM/ECF system. This 7th day of January 2010.

/s/ S. Derek Bauer S. Derek Bauer Georgia Bar No. 042537 MCKENNA LONG & ALDRIDGE LLP 303 Peachtree Street, Suite 5300 Atlanta, Georgia 30308 [phone] [phone] (facsimile)
ATLANTA:5200910.1

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