On August 22, 2016 a
Plaintiff's Motion for Entry of Scheduling Order - MOTION - ENTER ORDER
was filed
involving a dispute between
Theblaze Inc,
and
Balfe, Christopher,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
Preview
CAUSE NO. DC-16-10222
THEBLAZE INC. IN THE DISTRICT COURT OF
Plaintiff,
DALLAS COUNTY, TEXAS
CHRISTOPHER BALFE
Defendant. JUDICIAL DISTRICT
PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER
Plaintiff TheBlaze, Inc. TheBlaze files this Motion for Entry of Scheduling Order
(“Motion”) and states as follows:
This action deals with a straightforward, discrete issue: whether Defendant
Christopher Balfe is entitled to indemnification from TheBlaze in connection with another
ion pending in the 160th Judicial District Court of Dallas County, Texas.
This matter can be resolved expeditiously, with limited discovery.
Attached as Exhibit A is a proposed Scheduling Order, which sets forth proposed
dates for all applicable deadlines.
Accordingly, TheBlaze respectfully requests that the Court grant this Motion and
enter the attached Scheduling Order.
PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER
PAGE 1
WEST\271011665.1
Dated: September 6, 2016 Respectfully submitted,
/s/ Eliot Burriss
Eliot Burriss
Texas Bar No. 24040611
eli.burriss@dlapiper.com
DLA PIPER LLP (US)
1717 Main Street, Suite 4600
Dallas, TX 75201-4629
Telephone: 214.743.4500
Facsimile: 214.743.4545
Eric Ostroff (pro hac vice pending)
Florida Bar No. 10130
eostroff@melandrussin.com
Peter D. Russin (pro hac vice pending)
Florida Bar No. 765902
prussin@melandrussin.com
Meaghan E. Murphy (pro hac vice forthcoming)
Florida Bar No. 102770
mmurphy@melandrussin.com
MELAND, RUSSIN & BUDWICK, P.A.
3200 Southeast Financial Center
200 South Biscayne Boulevard
Miami, Florida 33131
Telephone: 305.358.6363
Facsimile: 305.358.1221
ATTORNEYS FOR PLAINTIFF
THEBLAZE INC.
PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER
PAGE 2
WEST\271011665.1
CERTIFICATE OF CONFERENCE
Pursuant to Local Rule 2.07, I, the undersigned attorney, hereby certify to the Court that I
counsel for Plaintiff conferred with counsel for Defendant in an effort to resolve the issues
contained in this Motion without the necessity of Court intervention. Counsel for Defendant
stated that Defendant believes the Motion is premature as Defendant intends to file a special
appearance. As a result, the Motion is opposed.
Certified to the 6th Day of September, 2016 by: /s/Eli Burriss
Eli Burriss
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Motion has been served upon all counsel of record in
accordance with the Texas Rules of Civil Procedure on this 6th day of September, 2016.
/s/ Eliot Burriss
Eliot Burriss
PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER
PAGE 3
WEST\271011665.1
Document Filed Date
September 06, 2016
Case Filing Date
August 22, 2016
Category
CNTR CNSMR COM DEBT
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CAUSE NO. DC-16-10222 THEBLAZE INC. IN THE DISTRICT COURT OF Plaintiff, DALLAS COUNTY, TEXAS CHRISTOPHER BALFE Defendant. JUDICIAL DISTRICT PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER Plaintiff TheBlaze, Inc. TheBlaze files this Motion for Entry of Scheduling Order (“Motion”) and states as follows: This action deals with a straightforward, discrete issue: whether Defendant Christopher Balfe is entitled to indemnification from TheBlaze in connection with another ion pending in the 160th Judicial District Court of Dallas County, Texas. This matter can be resolved expeditiously, with limited discovery. Attached as Exhibit A is a proposed Scheduling Order, which sets forth proposed dates for all applicable deadlines. Accordingly, TheBlaze respectfully requests that the Court grant this Motion and enter the attached Scheduling Order. PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER PAGE 1 WEST\271011665.1 Dated: September 6, 2016 Respectfully submitted, /s/ Eliot Burriss Eliot Burriss Texas Bar No. 24040611 eli.burriss@dlapiper.com DLA PIPER LLP (US) 1717 Main Street, Suite 4600 Dallas, TX 75201-4629 Telephone: 214.743.4500 Facsimile: 214.743.4545 Eric Ostroff (pro hac vice pending) Florida Bar No. 10130 eostroff@melandrussin.com Peter D. Russin (pro hac vice pending) Florida Bar No. 765902 prussin@melandrussin.com Meaghan E. Murphy (pro hac vice forthcoming) Florida Bar No. 102770 mmurphy@melandrussin.com MELAND, RUSSIN & BUDWICK, P.A. 3200 Southeast Financial Center 200 South Biscayne Boulevard Miami, Florida 33131 Telephone: 305.358.6363 Facsimile: 305.358.1221 ATTORNEYS FOR PLAINTIFF THEBLAZE INC. PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER PAGE 2 WEST\271011665.1 CERTIFICATE OF CONFERENCE Pursuant to Local Rule 2.07, I, the undersigned attorney, hereby certify to the Court that I counsel for Plaintiff conferred with counsel for Defendant in an effort to resolve the issues contained in this Motion without the necessity of Court intervention. Counsel for Defendant stated that Defendant believes the Motion is premature as Defendant intends to file a special appearance. As a result, the Motion is opposed. Certified to the 6th Day of September, 2016 by: /s/Eli Burriss Eli Burriss CERTIFICATE OF SERVICE I hereby certify that the foregoing Motion has been served upon all counsel of record in accordance with the Texas Rules of Civil Procedure on this 6th day of September, 2016. /s/ Eliot Burriss Eliot Burriss PLAINTIFF’S MOTION FOR ENTRY OF SCHEDULING ORDER PAGE 3 WEST\271011665.1