Public Engines v. Reportsee

Filing 57

Defendant's MOTION to Compel Discovery, MOTION for Sanctions filed by Defendant Reportsee. (Attachments: # 1 Text of Proposed Order) Motions referred to Samuel Alba.(Hunt, Jeffrey)

Public Engines v. Reportsee

Doc. 57

Jeffrey J. Hunt (5855) David C. Reymann (8495) PARR BROWN GEE & LOVELESS 185 South State Street, Suite 800 Salt Lake City, Utah 84111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] Walter E. Diercks (pro hac vice) RUBIN, WINSTON, DIERCKS, HARRIS, & COOK, LLP 1201 Connecticut Avenue NW, Suite 200 Washington, D.C. 20036 Email: [e-mail]

Joshua A. Glikin (pro hac vice) BOWIE & JENSEN, LLC 29 West Susquehanna Avenue Suite 600 Towson, Maryland 21204 Telephone: [phone] Facsimile: [phone] Email: [e-mail]

Attorneys for Defendant ReportSee, Inc. ______________________________________________________________________________ IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION

PUBLIC ENGINES, INC., a Delaware corporation, Plaintiff,

DEFENDANT'S MOTION TO COMPEL AND FOR SANCTIONS

Case No. 2:10-cv-317 vs. REPORTSEE, INC., a Delaware corporation, Defendant. Pursuant to Fed. R. Civ. P. 37(a) and (d), Defendant ReportSee, Inc. ("ReportSee"), moves this honorable Court for the entry of an order compelling Plaintiff, Public Engines, Inc. ("Public Engines") to supplement its document production to produce all documents that are responsive to Rule 34 requests for production served by ReportSee. In addition, ReportSee moves this Court to sanction Public Engines for its discovery failures. Judge Tena Campbell Magistrate Judge Samuel Alba

Dockets.Justia.com

For the reasons set forth in the accompanying Memorandum of Law, as well as any additional argument and evidence that may be presented in connection with any hearing ordered at the discretion of the Court, ReportSee respectfully requests that the Court grant ReportSee's Motion and award ReportSee with its expenses, including reasonable attorney's fees incurred in connection with this Motion. A proposed Order is attached. Respectfully submitted, Dated: November 2, 2010. __/s/ Joshua A. Glikin______ Joshua A. Glikin (#26852) [e-mail] BOWIE & JENSEN, LLC 29 W. Susquehanna Avenue Suite 600 Towson, Maryland 21204 [phone] Facsimile: [phone] and Jeffrey J. Hunt [e-mail] David C. Reymann [e-mail] PARR BROWN GEE & LOVELESS 185 South State Street Suite 800 Salt Lake City, Utah 84111 [phone] Facsimile: [phone] Counsel for Defendant, ReportSee, Inc.

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CERTIFICATE OF SERVICE I hereby certify that on the 2nd day of November 2010, I filed the foregoing DEFENDANT'S MOTION TO COMPEL AND FOR SANCTIONS via the CM/ECF system, which electronically served the following counsel of record: Alan L. Sullivan Todd M. Shaughnessy J. Elizabeth Haws SNELL & WILMER LLP 15 West South Temple, Suite 1200 Beneficial Tower Salt Lake City, Utah 84101-1004 Mark Lambert Mark Weinstein COOLEY GODWARD KRONISH, LLP Five Palo Alto Square Palo Alto, California 94306-2109

/s/ Jeffrey J. Hunt

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