Anderson v. Domino's Pizza, Inc. et al

Filing 107

MOTION for Summary Judgment by Cross Claimant Call-Em-All, LLC, Defendant Call-Em-All, LLC. Oral Argument Requested. (Attachments: # 1 Certification of Scott Shaffer, # 2 Exhibit 1-7, # 3 Proposed Order) Noting Date 9/7/2012, (Shaffer, Scott)

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UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WASHINGTON

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CIVIL ACTION NO.: C11-902-RBL
CAROLYN ANDERSON,

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Plaintiff,
v.

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[PROPOSED] ORDER ON
DEFENDANT CALL-EM-ALL, LLC’S
MOTION FOR SUMMARY JUDGMENT

DOMINO’S PIZZA, INC., DOMINO’S
PIZZA, LLC, FOUR OUR FAMILIES,
INC. and CALL-EM-ALL, LLC,

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Defendants.

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THIS MATTER having come before the Court upon Defendant Call-Em-All,
LLC’s Motion For Summary Judgment; and the Court having reviewed the following:

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1.

Defendant Call-Em-All, LLC’s Motion For Summary Judgment;

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2.

Declaration of Scott Shaffer, Esq. In Support Of Motion For Summary

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Judgment;
3.

Deposition testimony, discovery responses and other materials from this

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action submitted as exhibits to the Declaration of Scott Shaffer, Esq.;
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4.

Expert Report of Ray Horak with Exhibits thereto (ECF Document # 105);

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5.

___________________________________________________________;

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___________________________________________________________;

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7.

___________________________________________________________;

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8.

___________________________________________________________;

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[Proposed] Order on Summary Judgment–Page 1

OLSHAN FROME WOLOSKY LLP
PARK AVENUE TOWER
65 EAST 55TH STREET
NEW YORK, NY 10022
TEL [phone]

1705024-1

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and the Court having heard argument of counsel and being fully advised of the bases for

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the motion, now therefore:

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IT IS HEREBY ORDERED, ADJUDGED AND DECREED that Defendant Call-Em-

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All, LLC’s Motion For Summary Judgment be and is hereby GRANTED IN FULL;
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IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Amended

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Complaint is dismissed with prejudice as against Defendant Call-Em-All, LLC; and

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IT IS FURTHER ORDERED, ADJUDGED AND DECREED that summary judgment

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is granted in favor of Call-Em-All, LLC on the First Count of its Crossclaim against Four

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Our Families, Inc.

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DONE IN OPEN COURT this:_____________________________.

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_____________________________________
JUDGE

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Presented by:

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__________________________
Scott Shaffer (admitted pro hac)
OLSHAN FROME WOLOSKY LLP
-andCORR CRONIN MICHELSON
BAUMGARDNER & PREECE LLP

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Attorneys for Defendant Call-Em-All, LLC
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[Proposed] Order on Summary Judgment–Page 2

OLSHAN FROME WOLOSKY LLP
PARK AVENUE TOWER
65 EAST 55TH STREET
NEW YORK, NY 10022
TEL [phone]

1705024-1