Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 129

MOTION for Protective Order Compelling Heartland to Participate in the Discovery Process by Counter Claimant Forest River Inc. (Attachments: # 1 Affidavit Rule 26(c)(1) and L.R. 37.1 Certificate, # 2 Exhibit A - Corresp., # 3 Exhibit B - Corresp., # 4 Exhibit C - Resp. to Doc. Pro, # 5 Exhibit D - Resp. to Doc. Pro., # 6 Exhibit E - Not. of Dep., # 7 Exhibit F - Email, # 8 Exhibit G - Email, # 9 Exhibit H - Expert Memo, # 10 Exhibit I - Discovery Issues Summary Memo, # 11 Exhibit J - Email, # 12 Exhibit K - Email, # 13 Exhibit L - Email, # 14 Exhibit M - Email, # 15 Exhibit O - Email, # 16 Exhibit P - Email)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 129 Att. 12

Ryan Fountain
From: Ryan Fountain <[e-mail]> Monday, October 18, 2010 10:57 AM 'Smith, Melanie L.' 'Irmscher, David P.'; 'Meyer, Peter A.' RE: Heartland/Forest River forestriverheartlandirmscherOctlO.pdf

Sent:
To: Cc:

Subject: Attachments:

Melanie: Since Friday, I have been unable to obtain verification from the hotellP persons or my own ISP company that my email was actually sent or received. As I am sure you will understand, I am distressed when this sort of thing happens since it could compromise important confidential information rather unexpectedly. However, in the present case, there was nothing very confidential in the memo. Since you do not have it and I cannot find what happened to it, attached is another copy. Substantively, I do not think there is much in this that is different from what Dave and I discussed on October S, so I assume that by now Dave has some idea of what Heartland is willing to do in regards to these items. Also, as per my email of October 14, I need to hear from Dave with respect to the Donat transcript issues and the discovery due in the second suit. Please ask Dave to call me today to complete the Rule 37 process. Ryan From: Smith, Melanie L. [mailto:[e-mail]]

Sent: Monday, October 18, 2010 9:37 AM
To: Ryan Fountain Cc: Irmscher, David P.; Meyer, Peter A.

Subject: Heartland/Forest River
Mr. Fountain, Please resend your e-mail of October discuss further.

io".

Dave has checked his folders and does not have it. Please contact Dave to

Melanie Smith
Legal Secretary

T: 260.460.1709

I F: 260.460.1700 I
I
Fort Wayne, IN 46802

Baker & Daniels LLP
www.bakerdaniels.com 111 E. Wayne Street. Suite 800

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