Free Status Report - District Court of Connecticut - Connecticut

Case 3:02-cv-02234-AWT

Document 89

Filed 05/21/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (HARTFORD) ROBERT PAYNE and PAYNE INVESTMENTS LLC, Plaintiffs, v. TAYLOR VISION RESOURCES, TAYLOR STRATEGIC ACQUISITIONS, TAYLOR STRATEGIC DIVESTITURES, and TAYLOR FINANCIAL SERVICES LLC, all defendants collectively operating under the name TAYLOR COMPANIES, Defendants. MAY 21,2007 STATUS REPORT A telephone conference was held on May 16 and May 21,2007. The participants were Michael P. Berman and Jose A. Aguiar for the plaintiffs Robert Payne and Payne Investments LLC ("Plaintiffs"), and Douglas J. Varga for defendants Taylor Vision Resources, Taylor
Strategic Acquisitions, Taylor Strategic Divestitures, and Taylor Financial Services, LLC, all ("Defendants").

CN. ACTION NO.: 3:02CV02234 (AWT)

: :

defendants collectively operating under the name TAYLOR COMPANIES

BERMAN AND SABLE LLC ONE FINANCIAL PLAZA. HARTFORD. CONNECTICUT (860) 527-9699 . JURIS NO. 03840

06103

Case 3:02-cv-02234-AWT

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Counsel for both the Plaintiffs and the Defendants submit this Status Report and modification as to the items enumerated in the Rule 26(f) "Report of Parties Planning
Meeting" dated February 26,2004 ("26(f) Report"), on file in this Case.

I.

Case Management

Plan

A.

Standing Order on Scheduling in Civil Cases The parties request further modification of the deadlines in the "26(f) Report" as follows:

B.

Scheduling Conference with the Court No change.

C.

Early Settlement Conference 1. 2. The parties may request an early settlement conference. The parties prefer a settlement conference with a magistrate judge or other judicial officer the Court feels appropriate.

D.

Joinder of Parties and Amendment of Pleadings 1-2. No change (completed).

E.

Discovery 1-2. No change (completed).

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BERMAN AND SABLE LLC

ONE FINANCIALPLAZA,HARTFORD,CONNECTICUT06103 (860)527-9699 . JURIS NO. 03840

Case 3:02-cv-02234-AWT

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3-4.

Plaintiffs have requested that Defendants produce certain documents identified in a letter from Attorney Donohue (Plaintiffs' former counsel) to Attorney Poston (Defendants'
counsel) dated April 11, 2004 (but received on or about April

11,2005). Defendants voluntarily have agreed to produce documents in their possession and responsive to the categories of documents identified in Attorney Donohue's letter as Nos. 1 through 16, with the exception of Nos. 8,10,13, and 14. Defendants will produce those documents on or before June 15, 2007. The Plaintiffs reserve their right to file a Motion to Compel as to the documents sought in Nos. 8,10,13 and 14. Plaintiffs' counsel will confer in good faith with Defendants' counsel regarding the propriety and necessity of any such Motion before filing. Further, as stated in the continued deposition of Robert Payne
dated May 13, 2005, on page 106, Defendants will provide the

Plaintiffs with the Defendants' position as to whether or not the
Defendants agree or disagree that Mr. Payne performed all or

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BERMAN AND SABLE
ONE FINANCIAL PLAZA. HARTFORD, LLC CONNECTICUT 06103

(860)527-9699

.

JURIS NO. 03840

Case 3:02-cv-02234-AWT

Document 89

Filed 05/21/2007

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part ofthe tasks as he has denoted on exhibits 10, 11 and 12 of said deposition, on or before by June 15,2007. 5-9. F. No change (completed).

Dispositive Motions No change (moot).

G.

Joint Trial Memorandum The Joint Trial memorandum required by the Standing Order on Trial Memoranda in Civil Cases will be filed by November 15,2007.

II.

Trial Readiness The case will be ready for trial by January 2,2008.

THE PLAINTIFFS By: /s/ Michael P. Berman Federal Bar No. ct05624 mbennan01bennansable.com Jose A. Aguiar Federal Bar No. ct24658
iagui ar(a:!bem1ansab 1e. com

Berman and Sable LLC One Financial Plaza Hartford, CT 06103 (860) 527-9699 (telephone) (860) 527-9077 (facsimile)

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BERMAN AND SABLE LLC ONE FINANCIAL PLAZA, HARTFORD, CONNECTICUT 06103 (860) 527-9699 . JURIS NO. 03840

Case 3:02-cv-02234-AWT

Document 89

Filed 05/21/2007

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CERTIFICATION OF SERVICE This is to certify that on this 21stday of May, 2007, a copy of the foregoing Status Report was sent by electronic filing or mailed, via U.S. mail, first class, postage prepaid, on all counsel and pro se parties of record as follows:
Douglas J. Varga, Esq. Sarah W. Poston, Esq. Jacob D. Zeldes, Esq. Zeldes, Needle & Cooper, P.C. 1000 Lafayette Boulevard Bridgeport, CT 06601-1740 David Crystal, II, Esq. James P. Donohue, Jr., Esq. Crystal & Donohue 708 Third Avenue, 26th Floor New York, New York 10017

Jacob A. Stein, Esq. Stein, Mitchell & Mezines 1100 Connecticut Avenue, N.W. Washington, D.C. 20336

/s/ Jose A. Aguiar

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BERMAN AND SABLE LLC ONE FINANCIAL PLAZA. HARTFORD. CONNECTICUT 06103

(860)527-9699

.

JURIS NO. 03840