Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 145

MOTION to Compel Deposition of Heartland on Gain from Use of Master List by Counter Claimant Forest River Inc. (Attachments: # 1 Exhibit A - Notice of Deposition, # 2 Exhibit B - Excerpts of Donat deposition transcript, # 3 Exhibit D - Fountain corresp., # 4 Affidavit Cert under R37 and LR 37.1)(Fountain, Ryan)

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Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 145 Att. 4 UNITED STATES DISTRICT COURT Northern District of Indiana South Bend Division HEARTLAND RECREATIONAL VEHICLES, INC., Plaintiff, v. FOREST RIVER, INC., Defendant. ) ) ) ) CASE NO.:3:08-CV-490 ) ) ) CERTIFICATE UNDER FED. R. CIV. P. 37 AND L. R. 37.1 IN SUPPORT OF FOREST RIVER'S MOTION TO COMPEL DEPOSITION OF HEARTLAND ON GAIN FROM USE OF THE MASTER LIST The undersigned counsel certifies that on various occasions, including as detailed in the subject motion at pages 6-9 and Exhibit D thereof and on December 1, 2010, starting at approximately 10:00 a.m. and extending for approximately 17 minutes in a telephone conference call with David Irmscher and Peter Meyer, each counsel being present in their respective offices on each occasion, he made a good faith effort to resolve the discovery disputes of the subject motion without the need for Court action. Dated: December 8, 2010 Respectfully submitted, s/Ryan M. Fountain ___________________________ Ryan M. Fountain (8544-71) RyanFountain@aol.com 420 Lincoln Way West Mishawaka, Indiana 46544 Telephone: (574) 258-9296 1 Dockets.Justia.com Telecopy: (574) 256-5137 ATTORNEY FOR FOREST RIVER, INC. Certificate of Service I certify that on December 8, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF system, which sent notification of such filing to all of the parties through at least the following counsel of record: David P. Irmscher david.irmscher@bakerd.com s/Ryan M. Fountain _______________________ Ryan M. Fountain ATTORNEY FOR FOREST RIVER, INC. 2

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