Grochocinski v. Mayer Brown Rowe & Maw LLP et al

Filing 97

Plaintiff's Submission Regarding Dexia Credit Local v. Rogan by David Grochocinski (Attachments: # 1 Certificate of Service)(Carroll, Robert)

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS, EASTERN DISTRICT
DAVID GROCHOCINSKI, not individually,
but solely in his capacity as the Chapter 7
Trustee for the bankruptcy estate of
CMGT, INC.
Plaintiff,
v.
MAYER BROWN ROWE & MAW LLP,
RONALD B. GIVEN, and CHARLES W.
TRAUTNER,
Defendants.

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No. 06 C 5486
Judge Virginia M. Kendall
Magistrate Judge Morton Denlow

PLAINTIFF’S SUBMISSION REGARDING DEXIA CREDIT LOCAL V.
ROGAN, 231 F.R.D. 287 (N.D. Ill. 2005).
On May 14, 2008, this Court heard oral argument on Plaintiffs’ fully briefed
memorandum in support of his privilege log assertions. In Plaintiff’s opening brief, he cited
Dexia Credit Local v. Rogan, 231 F.R.D. 268 (N.D.Ill 2004) in support of his argument that the
“common interest” doctrine applies. During oral argument, this Court referred to Dexia Credit
Local v. Rogan, 231 F.R.D. 287 (N.D.Ill 2005.) Because that case was not addressed in the
parties’ briefs, this Court gave the parties leave to file a supplemental brief addressing that case’s
findings regarding the common interest doctrine. Plaintiff appreciates being given the
opportunity to file a brief addressing that case, but Plaintiff is going to stand on the arguments
submitted in his briefs and during oral argument.
Dated: May 19, 2008

Respectfully submitted,
DAVID GROCHOCINSKI, not individually,
but solely in his capacity as the Chapter 7
Trustee for the bankruptcy estate of
CMGT, INC.
BY: ____/s/ Robert D. Carroll___________
Plaintiff’s attorneys

Edward T. Joyce
Arthur W. Aufmann
Robert D. Carroll
EDWARD T. JOYCE & ASSOC., P.C. - Atty No. 32513
11 South LaSalle Street, Ste., 1600
Chicago, Illinois 60603