Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 127

REPLY to Response to Motion re 125 MOTION for Extension of Time to File Expert Report on Financial Issues and Amendment to Motion filed by Forest River Inc. (Attachments: # 1 Exhibit A - Declaration of Expert, # 2 Exhibit A - signature page, # 3 Exhibit A - attachment to Declaration, # 4 Exhibit B - Forest River 5th Prod. Req. and Resp., # 5 Exhibit C - Forest River 6th Prod. Req. and Resp., # 6 Exhibit D - Memo re Discovery Issues, # 7 Exhibit E - Forest River Notice of Dep., # 8 Exhibit F - counsel email, # 9 Exhibit G- counsel corresp., # 10 Exhibit H - counsel corresp.)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 127 Att. 8

Ryan Fountain
From: Ryan Fountain < [e-mail]> Monday, October 25, 2010 12:06 PM 'John LaDue' 'Irmscher, David P.'; 'Gallagher, Jerry' RE: HEartland v. Forest River: Gallagher Depositoin

Sent:
To:

Cc: Subject:

John, We have a hearing with the Court on the within the time limits you noted. Ryan From: John LaDue [mailto:[e-mail]] Sent: Monday, October 25, 2010 11 :22 AM To: Ryan Fountain Cc: Irmscher, David P.; Gallagher, Jerry Subject: RE: HEartland v. Forest River: Gallagher Depositoin Ryan: Jerry and I are available on either Nov. 17 or 18 in my office in South Bend. I would prefer the morning of November I will leave it to you and Dave Irmscher to determine whether taking further deposition testimony from Jerry is appropriate under the circumstances. If Jerry is required to provide further deposition testimony in this case, please note he has already been deposed for approximately 5 hours and 15 minutes (not including breaks). Under FRCP 30(d)(1), any additional deposition testimony from Jerry must be concluded in 1 hour and 45 minutes or less.

Ith,

so I would prefer the

is".

I fully expect the deposition to be completed

rz".

John

101m D. LaDue

Attorneys & Counselors at Law 200 First Bank Building 205 West Jefferson Blvd. South Bend, Indiana 46601 [phone] (office) [phone] (fax) [phone] (direct) [e-mail] www.lck-Iaw.com

LADUE I CURRAN I KUEHN

From: Ryan Fountain [mailto:[e-mail]] Sent: Sunday, October 24, 2010 3:42 PM To: John LaDue Subject: HEartland v. Forest River: Gallagher Depositoin John,

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