Gordon v. Impulse Marketing Group Inc

Filing 347

MEMORANDUM in Opposition re 344 MOTION to Strike, 339 MOTION to Strike Portions of Declarations of Third Party Defendants re: Motions to Compel and Disqualify for hearing without oral argument April 10, 2006 filed by Impulse Marketing Group Inc. (Ivey, Floyd)

Gordon v. Impulse Marketing Group Inc

Doc. 347

Case 2:04-cv-05125-FVS

Document 347

Filed 04/10/2006

FLOYD E. IVEY Liebler, Ivey, Connor, Berry & St. Hilaire 2 P. O. Box 6125 Kennewick, WA 99336-0125 3 5 0 9 -7 3 5 -3 5 8 1 Attorneys for Defendant 4 Impulse Marketing Group, Inc. and Third Party Plaintiff
1 5 6

Klein, Zelman, Rothermel, & Dichter, L.L.P. By: Sean Moynihan, Esq.; Peter Glantz 485 Madison Avenue 7 New York, New York 10022 Telephone Number [phone] 8 Facsimile Number [phone] Attorneys for Defendant 9 Impulse Marketing Group, Inc. and Third Party Plaintiff
10 11

ROBERT SIEGEL Attorney At Law 1325 Fourth Avenue, Suite 940 12 Seattle, WA 98101-2509 Attorney for Plaintiff
13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Third Party Plaintiff's Response to Third Party Defendant's Motion to Strike Motion to Strike Portions of Declarations - Page 1 of 2
LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON ) ) ) Pl a i n t i f f , ) vs. ) ) IMPULSE MARKETING GROUP, ) INC., ) ) Defendant ______________________________ ) ) ) IMPULSE MARKETING GROUP, ) INC., ) Third-Party Plaintiff, ) ) vs. ) ) BONNIE GORDON, et al., ) ) Third-Party Defendants. JAMES S. GORDON, JR., No. CV-04-5125-FVS DEFENDANT AND THIRD PARTY PLAINTIFF'S RESPONSE TO THIRD PARTY DEFENDANTS' MOTION TO STRIKE DEFENDANT AND THIRD PARTY PLAINTIFF'S MOTION TO STRIKE PORTIONS OF DECLARATIONS OF THIRD PARTY DEFENDANTS, INCLUDING MRS. BONNIE GORDON, MS. JAMILA GORDON, MR. JONATHAN GORDON AND MR. JAMES GORDON III AND OTHERS IN SUPPORT OF THIRD PARTY DEFENDANT'S MOTIONS TO COMPEL AND DISQUALIFY WITHOUT ORAL ARGUMENT

Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]

Dockets.Justia.com

Case 2:04-cv-05125-FVS

Document 347

Filed 04/10/2006

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21

Third Party Defendants have moved to strike Third Party Plaintiff's Motion to Strike portions of Declarations of Mrs. Bonnie Gordon, Ms. Jamila Gordon, Mr. Jonathan Gordon and Mr. James Gordon III which are filed in support of Third Party Plaintiffs' Motions to Compel and Disqualify. Third Party Plaintiff notes that the Third Party Defendant's have supplied Declarations with their Motion to Strike and that the Third Party Defendants' Motions to Compel and Disqualify are noted without oral argument on April 10, 2006. The Third Party Plaintiff requests that the Third Party Defendants' Motions be denied and in the alternative that the Third Party Defendants' be granted additional time to submit additional argument and evidence. DATED this 10th day of April, 2006. LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE s/ FLOYD E. IVEY Floyd E. Ivey, WSBA #6888 Attorneys for the Defendant Impulse

I hereby certify that on April 10, 2006, I electronically filed Defendant and Third Party Plaintiff's Response to Third Party Defendant's Motions to Strike Motion to Strike Declarations with the Clerk of the Court using the 22 CM/ECF System which will send notification of such filing to Robert Siegel, Peter J. Glantz and Sean A. Moynihan. I hereby certify that I have served the foregoing 23 to the following non-CM/ECF participants by other means: Bonnie Gordon, Jonathan Gordon, James S. Gordon, III, Robert Pritchett, Emily Abbey and Jamila 24 Gordon.
25 26 27 28
Third Party Plaintiff's Response to Third Party Defendant's Motion to Strike Motion to Strike Portions of Declarations - Page 2 of 2
LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE

S/ FLOYD E. IVEY FLOYD E. IVEY

Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]