Case 1:10-cv-10216-NMG Document 82
Filed 10/29/11 Page 2 of 3
Defendants further submit that this matter does not violate this Court’s Directive [Dkt. No. 76] of
October 14, 2011 since not only were Defendants unaware of the actions taken by Plaintiffs until October 25,
2011 (even though Plaintiffs’ counsel had a duty to inform Defendants’ counsel months earlier), but this is not a
discovery dispute, but rather a request for sanctions for violating this Court’s Protective Order and to right the
ongoing wrong improperly inflicted upon Defendants.
Defendants request to be permitted to file their EMERGENCY Motion for Sanctions with twenty-four
(24) pages. A copy of the EMERGENCY MOTION for Sanctions, without the exhibits, is attached hereto and
marked as Exhibit “A.” The Factual Background of Defendants’ EMERGENCY Motion for Sanctions ends on
page 13. Defendants’ Memorandum of Law begins on page 13 and concludes page 23 (11 pages), and page
24 is required for page of the signature block and the Certificate of Service.
CERTIFICATE UNDER LOCAL RULE 7.1(A)(2)
I certify that counsel for Defendants conferred with counsel for Plaintiff and Plaintiff objects to the filing
of the EMERGENCY MOTION for Sanctions. Counsel for Plaintiff requested that counsel for Defendants attach
Plaintiff’s October 28, 2011 letter in this section. A true and correct copy of Plaintiff’s October 28, 2011 letter is
attached hereto and marked as Exhibit “B”. A true and correct copy of Defendants’ response, dated October
28, 2011 is attached hereto and marked as Exhibit “C”.
Dated this 29th day of October, 2011.
IMPULSE SOFTWARE, et al
By its attorneys,
/s/ Terry M. Sanks___
BEUSSE WOLTER SANKS MORA & MAIRE, P.A.
Terry M. Sanks (Florida Bar No. 0154430)
Amber N. Davis (Florida Bar No. 0026628)
390 North Orange Avenue, Suite 2500
Orlando, Florida 32801
Telephone: (407) 926-7700
Facsimile: (407) 926-7720