Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 88

MOTION to Compel Production of Documents from Heartland and Baker & Daniels by Counter Claimant Forest River Inc. (Attachments: # 1 Exhibit A - Excerpt of '747 Patent, # 2 Exhibit B - Email of 3/14/05, # 3 Exhibit C - Excerpt of '841 Patent, # 4 Exhibit D - Excerpt of '650 Patent, # 5 Exhibit E - Excerpt of Taylor Dep., # 6 Exhibit F - FR Doc. Req. #9, # 7 Exhibit G - FR Doc. Req. #32, # 8 Exhibit H - Heartland Resp. to #9, # 9 Exhibit I - Heartland Resp. to #32, # 10 Exhibit J - B&D Subpoena, # 11 Exhibit K - Gallagher diary, # 12 Exhibit L - Brotherson CC, # 13 Exhibit M - Brotherson Letter, # 14 Appendix Rule 37 Certification, # 15 Supplement Supplement to Certification)(Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc

Doc. 88 Att. 13

case 3:08-cv-00490-TLS document 88-14

filed 02/01/10 page 1 of 2

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 TLS ) ) )

CERTIFICATE UNDER FED. R. CIV. P. 37(a)(1) AND L. R. 37.1 IN SUPPORT OF FOREST RIVER'S MOTION TO COMPEL DOCUMENT PRODUCTION FROM HEARTLAND AND BAKER & DANIELS

The undersigned counsel certifies that on various occasions, including January 11, 2010, starting at approximately 10:06 a.m. and extending for approximately 15 minutes in a telephone conference call with David Irmscher and Peter Meyer, and on January 21, 2010, starting at approximately 9:41 a.m. and extending for approximately 10 minutes in a telephone conference call with David Irmscher and Peter Meyer, each counsel being present in their respective offices on each occasion, and in subsequent email communications supplementing those calls, such as is attached hereto as a Supplement, he made a good faith effort to resolve the discovery disputes of the subject motion to compel without the need for Court action.

Dated: February 1, 2010

Respectfully submitted, s/Ryan M. Fountain ___________________________ Ryan M. Fountain (8544-71) [e-mail] 1

Dockets.Justia.com

case 3:08-cv-00490-TLS document 88-14

filed 02/01/10 page 2 of 2

420 Lincoln Way West Mishawaka, Indiana 46544 Telephone: [phone] Telecopy: [phone] ATTORNEY FOR DEFENDANT

Certificate of Service I certify that on February 1, 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 Abigail M. Butler [e-mail] [e-mail] s/Ryan M. Fountain _______________________ Ryan M. Fountain Attorney for Defendant Forest River, Inc.

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