STELOR PRODUCTIONS, INC. v. OOGLES N GOOGLES et al

Filing 275

Statement of Compliance with Local Rule 37.1 by STELOR PRODUCTIONS, LLC.. (Dorelli, Michael)

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION ) ) Plaintiff/Counter-Defendant, ) ) v. ) ) OOGLES N GOOGLES FRANCHISING, LLC, ) et. al. ) ) Defendants/Counter-Plaintiffs and . ) Third Party Plaintiff ) ) **************************************** ) ) OOGLES N GOOGLES FRANCHISING, LLC, ) ) v. ) ) STELOR PRODUCTIONS, LLC, ) ) Counter-Defendant, and ) ) STEVEN A. ESRIG, ) ) Third Party Defendant. ) STELOR PRODUCTIONS, LLC., Case No. 1:05-cv-0354-DFH-TAB PLAINTIFF/COUNTER-DEFENDANT'S STATEMENT OF COMPLIANCE WITH LOCAL RULE 37.1 Plaintiff/Counter-Defendant, Stelor Productions, LLC, by counsel, hereby submits this Statement of Compliance with Local Rule 37.1 and would respectfully show the Court as follows: In accordance with Local Rule 37.1, Plaintiff/Counter-Defendant and Defendants/Counter-Plaintiffs attempted to reach an informal resolution of the discovery dispute described in Plaintiff/Counter-Defendant's Motion for Protective Order, which is filed contemporaneously herewith. Specifically, counsel for Plaintiff/Counter-Defendant and Defendants/Counter-Plaintiffs engaged in the following efforts to reach an agreement with regard to disputes relating to written discovery propounded by the Defendants/Counter-Plaintiffs: 1. On October 8, 2008, counsel for Plaintiff/Counter-Defendant, Robert Merz, and counsel for Defendants/Counter-Plaintiffs, Steven Vaughan, conducted a teleconference in a good faith attempt to resolve the parties' discovery disputes without court action. 2. On October 17, 2008 counsel for Plaintiff/Counter-Defendant and counsel for Defendants/Counter-Plaintiffs conducted a teleconference in a second good faith attempt to resolve this dispute without court action. 3. The parties' efforts to reach agreement on the issues outlined in Plaintiff/Counter- Defendant's Motion for Protective Order were unsuccessful. Respectfully submitted, s/Michael A. Dorelli John David Hoover, Attorney No. 7945-49 Michael A. Dorelli, Attorney No. 20862-49 HOOVER HULL LLP 111 Monument Circle, Ste. 4400 P.O. Box 44989 Indianapolis, IN 46244-0989 Phone: (317) 822-4400 Fax: (317) 822-0234 E-mail: jdhoover@hooverhull.com mdorelli@hooverhull.com Robert Merz Stelor Productions, LLC 19110 Montgomery Village Avenue, #320, Montgomery Village, MD 20886 Tel: (301) 963-0000 Fax: (301) 740-7552 Email: b.merz@stelorproductions.com Attorneys for Plaintiff/Counter-Defendant, Stelor Productions, LLC 2 CERTIFICATE OF SERVICE I hereby certify that on October 27, 2008, a copy of the foregoing was filed electronically, and that notice of this filing will be sent to the following party by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. Stephen L. Vaughan Steve@IPLawIndiana.com s/ Michael A. Dorelli 3

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