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

Filing 37

Motion to excuse appearance at December 17, 2008 Status 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. 37

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. 1:08-CV-1761

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 12/17/2008 STATUS 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 status conference scheduled for December 17, 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. Further Defendant Ross Schilling is traveling on business in Europe and other representatives from Vector are in Nashville, Tennessee or are traveling elsewhere. It would constitute a significant burden for any of these parties to have to appear in person at the status conference. The primary reason for the parties' stipulated motion requesting an in-person conference was that the parties' attorneys believed that the attorneys (and the case) would benefit from an in-person conference rather than a telephonic status conference. However, should this Court require that representatives of these parties be available by phone, Mr. Jonathan Blaufarb, outside counsel to Freebird Film, Fly On, LSP, and Mr. Rossington, and Mr. Ken Levitan, of Vector, will be available at 2:00 p.m. EST on December 17, 2008. Lead counsel will be present at the status 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 December 10, 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 12/17/2008 STATUS 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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