Motion,Ex Parte: Sage-Popovich, Inc. v. Michigan Specialty Coatings, Inc.

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                                Filed: 8/3/2023 1:10 PM
                                                                                                                 Clerk
                                                                                              Porter County, Indiana




STATE OF INDIANA                      )        IN THE PORTER SUPERIOR COURT 2
                                      ) SS:    SITTING IN VALPARAISO
COUNTY OF PORTER                      )        CAUSE NO. 64D05-2304-PL-003077-SJ-JWC

SAGE-POPOVICH, INC.,                           )
                                               )
               Plaintiff,                      )
                                               )
vs.                                            )
                                               )
MICHIGAN SPECIALTY COATINGS,                   )
INC., d/b/a MSC FLOORS,                        )
                                               )
               Defendant.                      )

        DEFENDANT’S AGREED MOTION TO SET BRIEFING SCHEDULE ON
              PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT

        Defendant, by counsel, and in agreement with Plaintiff, by counsel, moves to set a briefing

schedule on Plaintiff’s Motion for Summary Judgment, and in support thereof states as follows:

        1.     Plaintiff filed its Motion for Summary Judgment on the issue of liability on July 12,

2023.

        2.     Counsel for the respective parties have discussed and agree that additional discovery

will be necessary in order for Defendant to respond to the Motion.

        3.     The parties have agreed to complete discovery necessary to respond to the Motion by

October 15, 2023.

        4.     The parties have also agreed that Defendant’s response to Plaintiff’s Motion for

Summary Judgment on or before November 15, 2023, and Plaintiff’s Reply in Support of its Motion

for Summary Judgment will be due December 1, 2023.

        WHEREFORE, the Defendant, by counsel, with agreement by Plaintiff, by counsel,

respectfully requests that the Court grant its Motion to Set Briefing Schedule on Plaintiff’s Motion

for Summary Judgment consistent with the dates set forth herein, and any other relief the Court

deems appropriate.
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                                              Respectfully submitted,


                                              /s/ R. Andrew Hahn
                                              R. Andrew Hahn, #25428-49
                                              Attorney for Defendant, Michigan Specialty
                                              Coatings, Inc. d/b/a MSC Floors



                                 CERTIFICATE OF SERVICE

        I certify that on the 3rd day of August 2023, I electronically filed the foregoing document
using the Indiana E-Filing System (IEFS). I also certify that on the above date, the foregoing
document was served upon the following person(s) via IEFS.

Jaime L. Turley Perz
jltp@sage-popovich.com

                                              /s/ R. Andrew Hahn
                                              R. Andrew Hahn, #25428-49


Selective Staff Counsel of Indiana
900 East 96th Street, Suite 425
Indianapolis, Indiana 46240
Office: (317) 815-4630
Direct: (317) 815-4649
Fax: (855) 515-8240




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