Gordon v. Impulse Marketing Group Inc

Filing 503

STATUS REPORT and CERTIFICATE RE DISCOVERY by James S Gordon, Jr. (Siegel, Robert)

Gordon v. Impulse Marketing Group Inc

Doc. 503

Case 2:04-cv-05125-FVS

Document 503

Filed 06/25/2007

iJustice Law, P.C. Robert J. Siegel 1325 Fourth Ave., Suite 940 Seattle, WA 98101 206-624-9392

THE HON. FRED VANSICKLE

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON AT RICHLAND ) ) Case No.: CV-04-5125-FVS ) vs. ) ) PROPOSED DISCOVERY PLAN; Impulse Marketing Group, Inc., ) STATUS REPORT CERTIFICATE ) Defendant ) ) ) ) Impulse Marketing Group, Inc., Third- ) ) Party Plaintiff, ) ) v. ) ) Bonnie F. Gordon, Jamila Gordon, ) ) James Gordon III, and Jonathan ) ) Gordon, Third-Party Defendants ) James S. Gordon, Jr., Plaintiff,

JOINT STATUS REPORT AND CERTIFICATE 1

i.Justice Law, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 206-304-5400 Fax: [phone]

Dockets.Justia.com

Case 2:04-cv-05125-FVS

Document 503

Filed 06/25/2007

Pursuant to the Court's May 30, 2007 Notice Setting Telephonic Scheduling Conference, Plaintiff hereby submits this Proposed Discovery Plan and Status Report Certificate

Proposed Discovery Plan Extensive written discovery has been propounded by both parties. Motions to compel have been filed, and are pending with this Court now for over one year. The discovery disputes have been referred to a court-appointed Discovery Master, also appointed over one year ago, who has yet to issue dispositive rulings on the matters before him. Pursuant to this Court's orders, Plaintiff has filed an Amended First Amended Complaint, and a More Definite Statement. None of these significantly change the underlying claims and issues in the case, and the discovery propounded by Plaintiff remains outstanding. Plaintiff proposes that the Discovery Master proceed to render rulings on the outstanding issues before him, and that the Court issue a new case schedule.

Status Certificate
a.

Issues Regarding Service of Process.

There are no issues regarding

service of process. All parties have been served.
b.

Issues Regarding Jurisdiction or Venue. regarding jurisdiction or venue.

There are no issues

JOINT STATUS REPORT AND CERTIFICATE 2

i.Justice Law, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 206-304-5400 Fax: [phone]

Case 2:04-cv-05125-FVS

Document 503

Filed 06/25/2007

c.

Motions Anticipated. summary judgment.

All parties anticipate bringing motions for

d.

Discovery Completed.

Discovery can be completed within 180 days

of the issuance of dispositive rulings by the Discovery Master.
e.

Special Procedures. The case has been referred to a Discovery Master for resolution of ongoing discovery disputes.

f.

Modifications to Standard Pretrial Procedures. to the standard procedures are necessary.

No modifications

g. h. i.

Bifurcation.

There is no need to bifurcate this case.

Prospects for Settlement. Settlement appears highly unlikely. Other Matters.
1.

So as to minimize expense use of electronic data transfer, and email communication will be utilized where appropriate.

The parties do not consent to a full-time Magistrate Judge to conduct all proceedings. DATED this 25th day of June, 2007. i.Justice Law, P.C. _/s/ Robert J. Siegel Robert J. Siegel WSBA# 17312 Attorney for Plaintiff

JOINT STATUS REPORT AND CERTIFICATE 3

i.Justice Law, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 206-304-5400 Fax: [phone]

Case 2:04-cv-05125-FVS

Document 503

Filed 06/25/2007

Certificate of Service I, hereby, certify that on June 25, 2007, we filed this pleading with this Court. The Clerk of the Court will provide electronic notification system using the CM/ECF, which will send an electronic copy of this Notice to: Floyd E. Ivey; Sean Moynihan; Stacy Wolery. I further certify that I have served the foregoing to the following non-CM/ECF participants by other means: Bonnie Gordon; Jonathan Gordon; James S. Gordon, III; Jamila Gordon; Emily Abbey; and Hon. Harld D. Clarke, Jr.

/S/ Robert J. Siegel Robert J. Siegel, WSBA #17312 Attorneys for Plaintiffs

JOINT STATUS REPORT AND CERTIFICATE 4

i.Justice Law, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 206-304-5400 Fax: [phone]