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

Doc. 73 Att. 1

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

CERTIFICATION OF GOOD FAITH ATTEMPT TO RESOLVE DISPUTE WITHOUT COURT ACTION In accordance with Federal Rule of Civil Procedure 26(c)(1), the undersigned counsel for Defendant LFP Publishing Group, LLC ("LFP") certifies that, before filing its Motion for Protective Order, respective counsel for the parties conferred in an effort to resolve this discovery dispute without Court action, without success. Respectfully submitted 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:5199318.1

Dockets.Justia.com

Atlanta, Georgia 30308 Ph: [phone]; Fx: [phone] Attorney for Defendant LFP Certificate of Service This is to certify that I have this day filed the within and foregoing CERTIFICATE OF GOOD FAITH DISCOVERY CONFERENCE 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)

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ATLANTA:5199318.1