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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Doc. 73 Att.

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

[PROPOSED] PROTECTIVE ORDER This matter having come before the Court on Defendant LFP's Motion for a Protective Order, the Court hereby finds that good cause exists for the entry of a protective order to strike 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. It is HEREBY ORDERED that Defendant LFP has no obligation to respond to Plaintiff's First Interrogatories Nos. 7 through 9; Plaintiff's First Request for

ockets.Justia.com

Production of Documents Nos. 2 through 7; or Plaintiff's Rule 30(b)(6) Notice of Deposition of LFP Topic Nos. 3, 4 and 8 through 11. SO ORDERED, this ____ day of _____________ 2010.

Hon. Thomas W. Thrash, Jr. United States District Court Judge PREPARED BY: S. Derek Bauer Georgia Bar No. 042537 MCKENNA LONG & ALDRIDGE LLP 303 Peachtree Street, Suite 5300 Atlanta, Georgia 30308 [phone] [phone] (facsimile) Attorneys for LFP Publishing Group, LLC d/b/a Hustler Magazine, et al.

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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 PROPOSED 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:5200923.1

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