Pinero v. Jackson Hewitt Tax Service Inc. et al

Filing 189

MOTION to Compel Discovery by Vicki L. Pinero. Motion(s) referred to Daniel E. Knowles, III. Motion Hearing set for 9/23/2009 11:00 AM before Magistrate Judge Daniel E. Knowles III. (Attachments: # 1 Certificate, # 2 Notice of Hearing, # 3 Memorandum in Support, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I)(Shartle, Bryan) Modified on 9/9/2009 to edit text (rll, ).

Pinero v. Jackson Hewitt Tax Service Inc. et al

Doc. 189

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA VICKI L. PINERO, individually and on ) behalf of all others similarly situated, ) ) Plaintiffs, ) ) v. ) ) JACKSON HEWITT TAX SERVICE ) INC.; JACKSON HEWITT INC.; and, ) CRESCENT CITY TAX SERVICE, ) INC. d/b/a JACKSON HEWITT TAX ) SERVICE, ) ) Defendants. ) Civil Action No. 08-03535 Sec. R JUDGE SARAH S. VANCE Mag. 3 MAGISTRATE KNOWLES, III JUDGE DANIEL E.

MOTION TO COMPEL NOW INTO COURT, through undersigned counsel and pursuant to Fed. R. Civ. P. 37 and L.R. 37.1, comes plaintiff, Vicki L. Pinero ("Plaintiff"), who moves this Court to compel defendants Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc. (jointly referred to as "Defendants") to properly respond to her 3 interrogatories and 7 document requests as more fully set forth in the attached supporting memorandum of law.

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WHEREFORE, considering the premises, the attached Fed. R. Civ. P. 37 and L.R. 37.1 Certificate, and the attached memorandum, Plaintiff requests the Court grant Plaintiff's Motion to Compel; compel Defendants to properly respond to Plaintiff's discovery; and, award Plaintiff all costs and attorneys' fees incurred in bringing this motion. Respectfully Submitted, /s/ Bryan C. Shartle David Israel (LSBA No. 7174) (T.A.) Bryan C. Shartle (LSBA No. 27640) Justin H. Homes (LSBA No. 24460)
SESSIONS, FISHMAN, NATHAN & ISRAEL, L.L.P.

CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing has been forwarded to all counsel of record by ECF; __ by email; __ by hand; __ by fax; __ by FedEx; __ by placing a copy of same in the U.S. Mail, postage prepaid this 8th day of September 2009. /s/ Bryan C. Shartle Bryan C. Shartle

3850 N. Causeway Blvd. Lakeway II, Suite 200 Metairie, Louisiana 70002 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff, Vicki L. Pinero

N:\1-DI-Non-Collector-Misconduct\Pinero, Vicki-Class Action\Pleadings\LA Lawsuit\Motion to Compel\2d Mot. to Complel\Motion to Compel.09.08.09.doc

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