1ST Class Legal (I.S.), Ltd. v. Niro, et al.

Northern District of Illinois, ilnd-1:2016-cv-06793

Request for Court to Schedule Status Conference by 1st Class Legal (I.S.), Ltd.

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Case: 1:16-cv-06793 Document #: 61 Filed: 09/01/17 Page 1 of 3 PageID #:708 MARC S. MAZER WEILL & MAZER, A Professional Corporation 90 New Montgomery Street Suite 1400 San Francisco, CA 94105 Telephone: (415) 421-0730 STEVE VARHOLA LYMAN LAW FIRM, LLC 227 West Monroe Street, Suite 2650 Chicago, Illinois 60606 Attorneys for Plaintiff and Counter Defendant 1st CLASS LEGAL (I.S.), LTD. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION 1st CLASS LEGAL (I.S.), LTD., a foreign) Case No.: 16-cv-6793 corporation,)) PLAINTIFF’S REQUEST FOR THE Plaintiff,) COURT TO SCHEDULE STATUS) CONFERENCE v.)) Honorable Robert M. Dow, Jr. RAYMOND NIRO, individually and doing) business as NIRO, HALLER & NIRO, an) Illinois Law Partnership, NIRO LAW, LTD.,) an Illinois Corporation, formerly known as) NIRO, HALLER & NIRO, LTD.,)) Defendants.)) and related Counter Claim s)) Plaintiff and Counter-Defendant 1st Class Legal (I.S.), Ltd. ("Plaintiff"), by and through its attorneys, respectfully requests that this Court schedule a status conference to address the issues described below. First, the Parties have completed two days of mediation and no settlement was reached. Second, this Court has taken under submission both of Plaintiff’s Motions for Summary Judgment with respect to the Counterclaim of Defendant Niro Law and its Motion to Amend the Complaint. Third, Plaintiff has scheduled the deposition of Bob Gordon, a managing agent of PLAINTIFF’S REQUEST FOR STATUS CONFERENCE CASE NO. 1:16-cv-06793 1 Case: 1:16-cv-06793 Document #: 61 Filed: 09/01/17 Page 2 of 3 PageID #:709 Plaintiff, so it commences on September 25, 2017 in England. Mr. Gordon’s deteriorating health issues require that his testimony be obtained quickly in lieu of live testimony at trial. WHEREFORE, Plaintiff and Counter-Defendant 1st Class Legal (I.S.), Ltd. respectfully requests this Court to schedule a status conference prior to September 25, 2017, to address the foregoing issues and any other issues that may be addressed at that time. Dated: September 1, 2017 Weill & Mazer, A Professional Corporation By:/s/Marc S. Mazer Marc S. Mazer WEILL & MAZER, A Professional Corporation 90 New Montgomery Street, Suite 1400 San Francisco, CA 94105 (415) 421-0730 Attorneys for Plaintiff and Counter-Defendant 1st Class Legal (I.S.), Ltd. PLAINTIFF’S REQUEST FOR STATUS CONFERENCE CASE NO. 1:16-cv-06793 2 Case: 1:16-cv-06793 Document #: 61 Filed: 09/01/17 Page 3 of 3 PageID #:710 CERTIFICATE OF SERVICE The undersigned, an attorney, certifies that on September 1, 2017, he caused the foregoing Plaintiff and Counter-Defendant’s, 1st CLASS LEGAL, LTD., Request for the Court to Schedule Status Conference to be served upon all counsel of record via the court’s electronic docketing system. Dated: September 1, 2017 1ST CLASS LEGAL (I.S.), LTD. By:/s/Steve M. Varhola Steve M. Varhola LYMAN LAW FIRM, LLC 227 West Monroe Street, Suite 2650 Chicago, Illinois 60606 (312) 762-9517 Attorneys for Plaintiff and Counter-Defendant 1st Class Legal (I.S.), Ltd. PLAINTIFF’S REQUEST FOR STATUS CONFERENCE CASE NO. 1:16-cv-06793 3