Toffoloni v. LFP Publishing Group, LLC

Filing 79

PROPOSED ORDER re: 77 Motion Hearing,,. (Solomon, Darrell)

Toffoloni v. LFP Publishing Group, LLC

Doc. 7

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

ORDER This matter having come before the Court on Defendant LFP Publishing Group, LLC's Motion for a Protective Order seeking to modify the place of deposition identified in Plaintiff's Rule 30(b)(6) Notice of Deposition of Defendant from Plaintiff's selection of Atlanta, to Los Angeles, California, where Defendant's principal place of business and corporate representatives reside; and the Court having reviewed written submissions and heard oral argument from the parties, the Court hereby finds that good cause exists for the entry of a protective order.

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Plaintiff has expressed her desire to be present for the deposition o f Defendant but represented to the Court, through her counsel, that she lacks the financial means to travel to California; and as an alternative to requiring its corporate representatives to travel to Atlanta for the deposition, Defendant LFP Publishing Group, LLC has offered to pay for Plaintiff's round trip airfare to Los Angeles and for one night's reasonable accommodations. Therefore, it is HEREBY ORDERED that Plaintiff's Rule 30(b)(6) Notice of Deposition of LFP Publishing Group, LLC will occur at the offices of McKenna Long & Aldridge LLP in Los Angeles, California, on a date convenient for the parties and their counsel; and it is further ORDERED that Defendant shall pay for one economy class round trip airfare for Plaintiff's travel to Los Angeles, California for the deposition of Defendant, and one night's hotel accommodation at a reasonable rate. SO ORDERED, this ____ day of _____________ 2010.

Hon. Thomas W. Thrash, Jr. United States District Court Judge

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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.

APPROVED AS TO FORM: Richard P. Decker Georgia Bar No. 215600 HALLMAN & WINGATE, LLC 166 Anderson Street, S.E. Suite 210 Marietta, GA 30060 [phone] Attorneys for Maureen Toffoloni

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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 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 21st day of January 2010.

/s/ Darrell J. Solomon Darrell J. Solomon Georgia Bar No. 305922 MCKENNA LONG & ALDRIDGE LLP 303 Peachtree Street, Suite 5300 Atlanta, Georgia 30308 [phone] [phone] (facsimile)
ATLANTA:5203686.1

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