97 Sugano's Motion for Attorney's Fees and Sanctions.pdf


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Case 2:11-cv-08305-ODW-PLA Document 97 Filed 11/27/12 Page 2 of 14 Page ID #:501

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pursuant to 15 U.S.C. § 1117(a) and this Court’s inherent power, Defendants

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KELLY SUGANO and TAKA-O, will move this Court for an order requiring

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Plaintiff SLEP-TONE ENTERTAINMENT CORPORATION and its counsel of

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record to pay attorneys’ fees to said Defendants in the amount of $19,330 and

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sanctions in the amount of $5,000.

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This motion is made following the conference of counsel pursuant to L.R. 7-

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3 that Defendants’ counsel noticed and initiated pursuant to the notice at 10:00

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a.m. on October 19, 2012, but in which Plaintiff’s counsel did not participate nor

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suggested any date to reschedule.

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This motion is based upon this notice of motion, the accompanying

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memorandum of points and authorities, the Declaration of J. Marie Gray, Esq. with

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Exhibits 1-5 thereto, the Declaration of Craig McLaughlin, Esq. with Exhibits 1-9

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thereto, other records and papers on file in this action, such further papers and

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records as may be submitted to the Court at or before the hearing on this motion

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and the oral argument of counsel at the hearing.

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Law Office of Craig McLaughlin

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Dated: November 27, 2012

By:

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/s/ Craig McLaughlin
Craig McLaughlin, Esq.
Attorney for Defendants
Kelly C. Sugano and Taka-O

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CORRECTED NOTICE OF MOTION AND MOTION BY DEFENDANTS
KELLY C. SUGANO AND TAKA-O FOR ATTORNEYS’ FEES AND SANCTIONS