Re: PACER
in response to
by
Message: PACER
Thanks Silver.
I believe e.DIGITAL legal team already expecting such a motion and documented
alternative objection for future reference or appeal . JMO
FROM DOC # 346
CONCLUSION
For the reasons stated above, e.Digital requests the entry of a corrected Amended
Scheduling Order, pursuant to Fed. R. Civ. P. 60(a), that clarifies the Court’s intent with respect
to §§ 6(g) (e-discovery costs), 8(b)(3) (depositions of prosecuting attorneys) and 8(b)(5)
(depositions of third parties) of the Amended Scheduling Order. If the Court does not believe a
corrected Amended Scheduling Order is necessary or appropriate with respect to any or all of
§§ 6(g), 8(b)(3) and 8(b)(5), e.Digital alternatively objects to the Amended Scheduling Order,
pursuant to Fed. R. Civ. P. 72(a) and Local Rule 30.2, and moves the Court to modify the
Amended Scheduling Order on the bases that §§ 6(g), 8(b)(3) and 8(b)(5) are clearly erroneous
and § 6(g)(4) is contrary to law for the reasons set forth above. For the Court’s convenience, a
proposed order that clarifies these three provisions of the Amended Scheduling Order in the
manner requested by e.Digital is attached hereto as Exhibit A.
Respectfully Submitted,
Dated: January 3, 2011 FAEGRE & BENSON, LLP
By: /s/ Jared B. Briant
Natalie Hanlon-Leh
Jared B. Briant
3200 Wells Fargo Center
1700 Lincoln Street
Denver , CO 80203-4532
Telephone: 303-607-3500
Email: nhanlon-leh@faegre.com
Email: jbriant@faegre.com
For the reasons stated above, e.Digital requests the entry of a corrected Amended
Scheduling Order, pursuant to Fed. R. Civ. P. 60(a), that clarifies the Court’s intent with respect
to §§ 6(g) (e-discovery costs), 8(b)(3) (depositions of prosecuting attorneys) and 8(b)(5)
(depositions of third parties) of the Amended Scheduling Order. If the Court does not believe a
corrected Amended Scheduling Order is necessary or appropriate with respect to any or all of
§§ 6(g), 8(b)(3) and 8(b)(5), e.Digital alternatively objects to the Amended Scheduling Order,
pursuant to Fed. R. Civ. P. 72(a) and Local Rule 30.2, and moves the Court to modify the
Amended Scheduling Order on the bases that §§ 6(g), 8(b)(3) and 8(b)(5) are clearly erroneous
and § 6(g)(4) is contrary to law for the reasons set forth above. For the Court’s convenience, a
proposed order that clarifies these three provisions of the Amended Scheduling Order in the
manner requested by e.Digital is attached hereto as Exhibit A.
Respectfully Submitted,
Dated: January 3, 2011 FAEGRE & BENSON, LLP
By: /s/ Jared B. Briant
Natalie Hanlon-Leh
Jared B. Briant
3200 Wells Fargo Center
1700 Lincoln Street
Denver , CO 80203-4532
Telephone: 303-607-3500
Email: nhanlon-leh@faegre.com
Email: jbriant@faegre.com
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