Reed et al v. Freebird Film Productions, Inc. et al

Filing 24

Motion to excuse appearance at Case Management Conference filed by Lynyrd Skynyrd Productions,Inc., Freebird Film Productions, Inc., Fly On, Inc., Vector Management, Inc., Gary Rossington, Ross Schilling. (Gott, Angela)

Reed et al v. Freebird Film Productions, Inc. et al

Doc. 24

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION REED, et al., Plaintiffs, vs. FREEBIRD FILM PRODUCTIONS, INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

JUDGE CHRISTOPHER A. BOYKO CASE NO. 1:08CV1761

MOTION TO EXCUSE THE ATTENDANCE OF DEFENDANTS FREEBIRD FILM PRODUCTIONS, INC., FLY ON, INC., VECTOR MANAGEMENT, INC., GARY ROSSINGTON, ROSS SCHILLING, AND LYNYRD SKYNYRD PRODUCTIONS, INC. FROM THE CASE MANAGEMENT CONFERENCE

Defendants Freebird Film Productions, Inc. ("Freebird Film"), Fly On, Inc. ("Fly On"), Vector Management, Inc. ("Vector"), Gary Rossington, Ross Schilling, and Lynyrd Skynyrd Productions, Inc. ("LSP"), hereby respectfully move this Court for leave not to appear in person at the case management conference scheduled for September 29, 2008 in this case. The reasons for the requested excused absences for Freebird Film, Fly On, Gary Rossington, and LSP are that Freebird Film is a corporation headquartered in Florida, Fly On and LSP are Florida corporations with principal places of business in California, and Mr. Rossington,

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the President of these companies, resides in the Atlanta, Georgia metropolitan area. It would constitute a significant burden for any of these parties, and in particular Mr. Rossington, to have to appear in person at the case management conference. The reasons for the requested excused absences for Vector and Ross Schilling are that Vector is a Tennessee company headquartered in the Nashville metropolitan area, and Mr. Schilling resides and primarily works in the Nashville metropolitan area, and it would constitute a significant burden for either to have to appear in person at the case management conference. Should this Court require that representatives of these parties be available by phone, Mr. Schilling, on behalf of himself and Vector, and Mr. Jonathan Blaufarb, outside counsel to Freebird Film, Fly On, LSP, and Mr. Rossington, will be available at 2:00 p.m. EST on September 29, 2008. Lead counsel will be present at the case management conference.

Respectfully submitted, /s/ Angela R. Gott________________ MARK E. AVSEC (0064472) [e-mail] BRYAN A. SCHWARTZ (0078527) [e-mail] ANGELA R. GOTT (0082198) [e-mail] BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP 200 Public Square, Suite 2300 Cleveland, Ohio 44114-2378 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Freebird Film Productions, Inc., Fly On, Inc., Vector Management, Inc., Gary Rossington, Ross Schilling, and Lynyrd Skynyrd Productions, Inc.

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CERTIFICATE OF SERVICE I hereby certify that on September 16, 2008, a copy of the foregoing MOTION TO EXCUSE THE ATTENDANCE OF DEFENDANTS FREEBIRD FILM PRODUCTIONS, INC., FLY ON, INC., VECTOR MANAGEMENT, INC., GARY ROSSINGTON, ROSS SCHILLING, AND LYNYRD SKYNYRD PRODUCTIONS, INC. FROM THE CASE MANAGEMENT CONFERENCE was filed electronically. Notice of this filing will be sent by operation of the Court's electronic filing system to all parties. Parties may access this filing through the Court's system.

/s/ Angela R. Gott ANGELA R. GOTT (0082198)

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