Roger Cleveland Golf Company Inc v. Prince et al

Filing 15

Local Rule 26.01 Answers to Interrogatories by Christopher Prince, Prince Distribution LLC.(Lizzi, Christopher) Modified to remove duplicative text on 9/18/2009 (asni, ).

Roger Cleveland Golf Company Inc v. Prince et al

Doc. 15

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION ROGER CLEVELAND GOLF COMPANY, INC., ) ) ) ) ) VS. ) ) CHRISTOPHER PRINCE, SHELDON SHELLEY, ) AND PRINCE DISTRIBUTION, LLC ) ) ) Defendants ) __________________________________________) Plaintiff, CHRISTOPHER PRINCE AND PRINCE DISTRIBUTION, LLC'S RESPONSES TO LOCAL CIVIL RULE 26.01 DSC INTERROGATORIES Pursuant to Local Civil Rule 26.01 DSC, Defendant's Christopher Prince and Prince Distribution, LLC., answer as follows: (A) State the full name, address and telephone number of all persons or legal entities who CIVIL ACTION NO: CA NO: 2:09 CV 02119 MBS

may have a subrogation interest in each claim and state the basis and extent of said interest. ANSWER: (B) Defendant is not aware of any at this time.

As to each claim, state whether it should be tried jury or non-jury and why. In its Answer, Plaintiff has requested a jury-trial on all its defenses.

ANSWER:

Defendant believes that issues of fact affect each of its claims in this case and are appropriate for jury resolution. (C) State whether the party submitting these responses is a publicly owned company and

separately identify: (1) each publicly owned company of which it is a parent, subsidiary, partner, or affiliate; (2) each publicly owned company which owns ten percent or more of the outstanding shares

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or other indicia of ownership of the party; and (3) each publicly owned company in which the party owns ten percent or more of the outstanding shares. ANSWER: Defendant is not a publicly owned entity and no publicly held

corporation owns 10% or more of its stock. Defendants indirect, ultimate parent corporation is Prince Distribution, LLC., which is not publicly traded in the United States. (D) State the basis for asserting the claim in the division in which it was filed (or the

basis of any challenge to the appropriateness of the division). ANSWER: The subject case was filed in the Charleston Division of the United States

District Court for the District of South Carolina as the defendants reside within the jurisdiction of the Charleston Division pursuant to 28 USC § 1391 (b) and (c). (E) In this action related in whole or in part to any other mater filed in this District,

whether civil or criminal? If so, provide (1) a short caption and the full case number of the related action; (2) an explanation of how the matters are related; and (3) a statement of the status of the related action. Counsel should disclose any cases which may be related regardless of whether they are still pending. Whether cases are related such that they should be assigned to a single judge will be determined by the Clerk of Court based on a determination of whether the cases: arise from the same or identical transactions, happenings, or any other reason would entail substantial duplication of labor if heard by different judges. ANSWER: (F) No.

If the defendant is improperly identified, give the proper identification and state

whether counsel will accept service of an amended summons and pleading reflecting the correct identification. ANSWER: N/A

(G)

If you contend that some other person or legal entity is, in whole or part, liable to you

or the party asserting a claim against you in this matter, identify such person or entity and describe the basis of said liability. ANSWER: Defendant is not aware of any at this time.

LIZZI LAW FIRM, P.C.

S/ Christopher D. Lizzi _____________________________ Christopher D. Lizzi Federal Bar Number: 8040 Attorney for Defendant 2170 Ashley Phosphate Road, Suite 402 North Charleston, SC 29406 North Charleston, South Carolina September 17, 2009

CERTIFICATE OF SERVICE

I, Melisa L. Barbosa, hereby certify that this document has been filed through the ECF system and will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non-registered participants on this date. S/ Melisa L. Barbosa ___________________________ Melisa L. Barbosa

Date: September 17, 2009