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JOINT STATUS REPORT AND
DISCOVERY PLAN - 1
(NO. 2:17-CV-00327-TSZ)


LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

THE HONORABLE THOMAS S. ZILLY









UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON
HARMONY GOLD U.S.A., INC.,

Plaintiff,

v.


HAREBRAINED SCHEMES LLC,
HAREBRAINED HOLDINGS, INC.,
JORDAN WEISMAN, PIRANHA GAMES
INC., INMEDIARES PRODUCTIONS, LLC.,
and DOES 1

10
,
Defendants.

CASE NO. 2:17-CV-00327-TSZ



JOINT STATUS REPORT AND
DISCOVERY PLAN
Plaintiff Harmony Gold U.S.A., Inc., (“Plaintiff”) and Defendants Harebrained Schemes
LLC, Harebrained Holdings, Inc., Jordan Weisman and Piranha Games Inc. (“Defendants”) submit
this Joint Status Report in accordance with Fed. R. Civ. P. 26(f), Local Rule 26(f) and the Court’s
Order. (Dkt. No. 14.) 1. Nature and Complexity of the Case.
STATEMENT OF PLAINTIFF
This case involves two claims. First, Plaintiff alleges that all Defendants have willfully
infringed, and are continuing to infringe, its registered United States copyrights to its “Robotech”
animated giant warrior robots, which Plaintiff has offered, sold, licensed and used in the United
States for animated televised programs, books, comic books and other materials. Plaintiff alleges that
Defendants Harebrained Schemes LLC, Harebrained Holdings, Inc., and Jordan Weisman (the
“Harebrained Defendants”) have created animated warrior robots for their upcoming “BattleTech” Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 1 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 2
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

PC game which infringe its Robotech copyrights. In regard to Defendant Piranha Games Inc.
(“Piranha”), Plaintiff alleges that Piranha has created and is using images of warrior robots in its
MechWarrior Online game that infringe its Robotech copyrights, after seeking and being refused a
license from Plaintiff to use those images. Plaintiff also alleges that Piranha Games has provided
Catalyst Game Labs
(“Catalyst”)
images of warrior robots which infringe Plaintiff’s Robotech
copyrights, and which Catalyst has included in its works. Plaintiff
recently joined the parent
company of Catalyst Game Labs, InMediaRes Productions, LLC, as an additional defendant in this
case.
Second, Plaintiff alleges that the Harebrained Defendants have breached the
Settlement

Agreement and Mutual General Release

into which Plaintiff and Mr. Weisman entered in December
1996. In the 1996 agreement, which was entered pursuant to a lawsuit for copyright infringement
against Mr. Weisman and certain of his business partners, Mr. Weisman agreed that he would not
“make any use, and will not authorize [his] licensees to make any use, of the visual design images of
the twelve (12) Battlemechs listed below except as provided in this agreement.” Plaintiff alleges that
Mr. Weisman’s current infringement of Plaintiff’s Robotech copyrights


including infringement
through companies he controls, viz., the Harebrained companies — constitutes a breach of the 1996
settlement agreement.

STATEMENT

OF DEFENDANTS PIRANHA AND THE HAREBRAINED DEFENDANTS
This is a copyright infringement case with a complicated history and multiple entities,
stemming from a copyright litigation i
n the 1990s and a settlement of that litigation in 1996.
Because of this twenty-plus year history and multiple entities involved asserted herein, as well as the
multiple copyrights involved in the action, Defendants believe that the trial should be schedu
led
approximately sixteen months from the filing of this Joint Status Report.

As a result of
the litigation in the 1990’s, Harmony Gold allegedly obtained, or retained,
rights in some or all of the images that are at issue in this litigation. These images are of robot
warriors. It is critical to the issues in this litigation (e.g., ownership) to determine
how and
what, if
any, rights the Plaintiff obtained, or retained, as a result of that settlement agreement or otherwise. Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 2 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 3
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

Prior to filing
this case
,
Plaintiff’s counsel stated that the parties to the agreement required
confidentiality of the terms of the agreement, so Plaintiff’s counsel was not free to share the
agreement with Piranha
.
Prior to when the Plaintiff filed the Complaint, Plaintiff asserted rights to the robot warrior
images set out in the Complaint. Because of that assertion, in an effort to avoid litigation, and at
plaintiff’s request, Piranha provided some images of robot warriors to Plaintiff in order to determine
whether Plaintiff would object to them. Piranha wished to use these images commercially, but did
not want to do so if litigation would ensue. After providing Plaintiff with the opportunity to inspect
and provide input on at least two occasions, it became clear to Piranha that Plaintiff would object to
Piranha’s commercial use of virtually any image of a robot warrior. So
,

Piranha
set out to crea
te all
new original artwork for its robot warriors for the MechWarrior Online game without further
communication with Plaintiff.
The
accused
robot warrior images of Piranha and the Harebrained Defendants are not
substantially similar to those of Plaintiff. Plaintiff’s theory of liability appears to be that any robot
warrior image is substantially similar to the images of Plaintiff’s robot warriors. While the images
of Plaintiff and
Defendants are both images of robot warriors, there are significant differences
between them such that they are not substantially similar. In fact, there are multiple third parties
who also produce images of robot warriors.
Defendants’ images are no closer to the images of
Plaintiff than are the third party images.
Piranha has not provided Catalyst Game Labs or
InMediaRes Productions, LLC with images of warrior robots, and Catalyst and InMediaRes
Productions, LLC do not have a license to use any of Piranha’s artwork. Defendants deny Plaintiff’s
allegations of,
inter alia, copyright infringement, whether willful or innocent, and have asserted
numerous defenses, including noninfringement, the scenes a faire doctrine, and the merger doctrine,
among others. The Harebrained Defendants further deny the breach of contract allegations.
2.
Proposed Deadline for Joining Additional Parties. August 8, 2017.
3.
Assignment of Case to Magistrate Judge: No.
4.
Discovery Plan: Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 3 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 4
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

A. Initial Disclosure Deadline: May 8, 2017
B. Subjects of Discovery: The parties anticipate discovery relating to the Plaintiff’s
Robotech copyrights; Plaintiff’s business relating to the Robotech copyrights;
Defendants’ access to images of Plaintiff’s Robotech warrior robots; Defendants’
creation, sale, distribution, licensing, marketing, display and other uses of images of
warrior robots that Plaintiff alleges infringe its Robotech copyrights;
Defendants’
revenues from their creation, sale, distribution, licensing, marketing, display and other
uses of images of warrior r
obots
that Plaintiff alleges infringe its Robotech copyrights;
business relationships between
and among the Defendants, as well as between the
Defendants and Catalyst Game Labs; the prior litigation between Plaintiff and Mr.
Weisman and his business associates, and the settlement agreement related thereto;
Plaintiff’s damages on account of
Defendants’ copyright infringement and breach of
contract; and the creation, display, and use of images of warrior robots by third parties.
The parties do not believe that discovery should be conducted in phases or be limited to,
or focused upon, particular issues.
C. The parties agree that by July 10, 2017, each party shall disclose:
1.
Custodians. Between three and seven custodians most likely to have discoverable ESI
in their possession, custody or control. The custodians shall be identified by name, title,
connection to the instant litigation, and the type of information under his/her control.
This initial disclosure is not a limit on further discovery regarding other
custodians who
may have discoverable ESI in their possession, custody, or control.

2.
Non-Custodial Data Sources. A list of non-custodial data sources (e.g. shared drives,
servers, etc.), if any, likely to contain discoverable ESI.
3. Absent a showing of good cause by the requesting party, the parties shall not be required
to modify the procedures used by them in the ordinary course of business to back
-up
and archive data; provided, however, that the parties agree to preserve all discoverable
ESI in their possession, custody or control. The parties understand that this may require Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 4 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 5
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

disabling or modifying any auto
-delete functions in order to avoid deletion of
discoverable ESI. All parties shall supplement their disclosures in accordance with
Rule 26(e) with discoverable ESI responsive to a particular discovery request or
mandatory disclosure where that data is created after a disclosure or response is made
.
4. Absent a showing of good cause by the requesting party, the following categories of
ESI need not
be preserved:

a.
Deleted, slack, fragmented, or other data accessible only by forensics.
b.
Random access memory (RAM), temporary files, or other ephemeral data that is difficult to preserve without disabling the operating system.
c.
On-line access data such as temporary internet files, history, cache, cookies, and
the like.

d.
Data in metadata fields that are frequently updated automatically, such as last-
opened dates.
e.
Back-up data that are substantially duplicative of data that are more accessible
elsewhere.
f.
Server, system, or network logs.
g. Electronic data (e.g. email, calendars, contact data, and notes) sent to or from mobile devices (e.g., iPhone, iPad, Android, and Blackberry devices), provided that a copy of all such electronic data is routinely saved elsewhere (such as on a server,
laptop, desktop computer, or “cloud” storage).
5.
The parties agree that ESI discovery shall be subject to the following rules:
a. Search methodology. The parties shall attempt to reach agreement on appropriate
search terms, or an appropriate computer- or technology-aided methodology,
before any such effort is undertaken.
b.
The producing party shall search both non-custodial data sources and ESI
maintained by the custodians identified above.
Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 5 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 6
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

c. Format. The parties have exchanged and agreed upon their preferred document
production formats.
d.
Metadata fields. If the requesting party seeks metadata, the parties agree that only the
following metadata fields need be produced: document type; custodian; author/from;
recipient/to, cc and bcc; title/subject; file name and size; original file path; date created,
sent, modified and/or received; and hash value.
D. The parties do not anticipate any privilege issues. At a later date, the parties will discuss
in
good faith and reach agreement on the appropriate deadline for exchanging privilege
logs. The parties agree that privileged and work product documents created subsequent to
January 1, 2017,

do not need to be logged. The parties agree to promptly return or
sequester any document identified by an opposing party as privileged or work product but
which was inadvertently produced.
E. The parties do not anticipate any limitations on discovery, and they will seek written discovery and the depositions of relevant witnesses. The parties expect to be able to cooperate in resolving issues that could lead to discovery abuse. Accordingly, the parties believe there is presently no need to impose any limitations on discovery.
F. The parties will prepare and submit to the Court for entry a Protective Order to govern the disclosure and use of confidential information. The parties anticipate that they will
not need the Court’s intervention to resolve any disputes relating to the terms of this
Protective Order.
The parties have agreed to service of papers (other than original
process) by email, with service effective on the date emailed. Three days will
not be
added to the time provided for responses served by email.

The parties are not presently
aware of any other orders that should be entered by the Court under FRCP 26(c) or under
Local Rule CR 16(b) and (c).

5.
Items in Local Rule 26(f)(1).
A. The parties have conferred and believe that prompt resolution of this case is not
possible at this time. However,
the parties desire a fair, reasonable, and early Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 6 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 7
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

resolution to this case and will pursue all opportunities to achieve such a resolution.
The parties propose that this case be set for trial the week of September 25, 2018.
B. The parties agree that mediation is the preferred method of Alternative Dispute
Resolution. The parties request that the mediation deadline be set after the close of
discovery and the dispo
sitive motions deadline. The parties will seriously consider
pursuing mediation much earlier than that, but request a later deadline in case the
parties decide, as the case develops, that an early mediation is not likely to be
successful.
C. Related cases: none.
D. Discovery Management and Other Dates: The parties suggest the following dates for
discovery and other matters:
Action Date
Deadline to Join Additional Parties August 8, 2017
Parties Serve Initial Expert Reports February 19, 2018
Parties Serve Rebuttal Expert Reports March 19, 2018
Parties Serve Reply Expert Reports
STATEMENT OF PLAINTIFF
Plaintiff asks that reply expert reports be
permitted and filed, if the parties choose
to do so, no later than April 9, 2018

STATEMENT OF DEFENDANTS
PIRANHA A
ND THE
HAREBRAINED DEFENDANTS
Defendants Piranha and the Harebrained
Defendants do not agree to a reply expert
report deadline and object to its inclusion
because (1) reply expert reports are likely
to be unnecessary in this case and will
result in signifi
cant, additional, expenses
to the parties; (2) Fed. R. Civ. P.
26(a)(2)(D) and the Local Civil Rules do
not provide for reply expert reports; (3)
improper material submitted in or with
rebuttal reports may be addressed with
motions to strike or other Court relief (see
Shinsedai Co. v. Nintendo Co., 2014 U.S. Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 7 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 8
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

Action Date
Dist. LEXIS 191136 (S.D. Cal. Jun. 10,
2014); and (4) where the parties do not
agree to the inclusion of reply expert
reports and they are not specifically
allowed by local rules, courts typically
permit reply expert reports only by leave
of Court for cause.
See Cadence Pharms.,
Inc. v. Fresenius Kabi USA, LLC, 2014
U.S. Dist. LEXIS 194779 (S.D. Cal. Jun.
2, 2014);
Ironshore Ins., Ltd. v. W. Asset
Mgmt. Co.
, 2013 U.S. Dist. LEXIS 69404
(S.D.N.Y. May 15,

2013);
Sanofi-Aventis
v. Barr Labs.
, 598 F. Supp. 2d 632 (D.N.J.
2009).

Close of Discovery and Deadline for Parties to
Submit Discovery Motions
April 30, 2018

Last Day to File Dispositive Motions May 30, 2018
Mediation Deadline June 29, 2018
Motions in Limine Filing Deadline July 31, 2018
Hearing on Dispositive Motions TBD by Court
Final Pretrial Conference TBD by Court
E. Anticipated discovery sought: See Section 4.B., above.
F. Phasing of motions: The parties do not anticipate that it will be necessary to phase
motion practice in this case.

G. Preservation of discoverable information: The parties are preserving discoverable
information, and have issued litigation holds regarding the same.
H. Privilege issues: See Section 4.D., above.
I. Model Protocol for Discovery of ESI: The parties agree to follow the Model Protocol
for Discovery of ESI, with agreed-upon amendments to the same as the parties deem
appropriate for this case.
J. Alternatives to Model Protocol: See Section 5.I., above. Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 8 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 9
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

6.
Discovery Completion Date: April 30, 2018.
7.
The parties do not believe there is a need for this case to be bifurcated.
8.
Pretrial Statements and Pretrial Order: At this time, the parties do not request any
changes to the pretrial statements and pretrial order called for by Local Rules 16(e), (h),
(i), and (k), and 16.1.
9.
The parties have no suggestions regarding shortening or simplifying this case.
10.
Anticipated Trial Date: The parties anticipate a five-day trial starting on September 25,
2018.

11.
Jury or Non-Jury: Defendants have requested a jury for the trial.
12.
Length of Trial: The parties anticipate that this will be a five-day trial.
13.
Trial Counsel:
For Plaintiff:
Brett A. August
Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP
200 South Wacker Drive, Suite 2900

Chicago, Illinois 60606
(312) 554
-8000

Jason Koransky
Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP
200 South Wacker Drive, Suite 2900

Chicago, Illinois 60606
(312) 554
-8000

Damon
Elder
Calfo Eakes & Ostrovsky PLLC
1301 Second Avenue, Suite 2800

Seattle, Washington 98101

Telephone: (206) 407-2222

Andrew Hughes
Calfo Eakes & Ostrovsky PLLC
1301 Second Avenue, Suite 2800

Seattle, Washington 98101
Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 9 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 10
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

Telephone: (206) 407-2222

For Defendants:
Defendant Piranha:
Paul T. Meiklejohn

Dorsey & Whitney LLP
701 Fifth Avenue, Suite 6100

Seattle, WA 98104

Telephone: (206) 903-8746

J. Michael Keyes
Dorsey & Whitney LLP
701 Fifth Avenue, Suite 6100

Seattle, WA 98104

Telephone: (206) 903-8757

Ryan B. Meyer
Dorsey & Whitney LLP
701 Fifth Avenue, Suite 6100

Seattle, WA 98104

Telephone: (206) 903-8768
Harebrained Defendants:
Warren J. Rheaume

Davis Wright Tremaine LLP
1201 Third Avenue, Suite 2200

Seattle, WA 98101

Telephone: (206) 757-8265

James H.
Corning
Davis Wright Tremaine LLP
1201 Third Avenue, Suite 2200

Seattle, WA 98101

Telephone: (206) 757-8253

14.
Unavailable Dates for Trial: Assuming trial takes place in September, 2018 or later, the
parties are not currently aware of any complication to be
considered when setting a trial
date.
Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 10 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 11
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

15.
Service: Except for Catalyst, all current parties have been served. To the extent that either
party seeks to join additional parties, service on those parties will be effected in a timely
manner.
16.
Scheduling Conference: The parties do not request a scheduling conference.
17.
Rule 7.1 and Local Rule 7.1 Statements: Plaintiff filed its statement on March 1, 2017.
The Harebrained
Defendants
and Piranha
filed their statements on April 24, 2017.

DATED May 8, 2017.
CALFO EAKES & OSTROVSKY PLLC

By s/ Damon C. Elder____________________
Damon C. Elder, WSBA #46754

Andrew R.W. Hughes, WSBA #49515

1301 Second Avenue, Suite 2800

Seattle, WA 98101-3808 Phone: (206) 407-2200 Fax: (206) 407-2224 Email: [email protected]

[email protected]


Brett A. August (admitted pro hac vice) [email protected] Jason Koransky (admitted pro hac vice) [email protected] Pattishall, McAuliffe, Newbury, Hilliard & Geraldson LLP 200 South Wacker Drive, Suite 2900 Chicago, Illinois 60606 Telephone: (312) 554-8000 Facsimile: (312) 554-8015 Attorneys for Plaintiff Harmony Gold U.S.A., Inc.
DORSEY & WHITNEY LLP

By__s/ Paul T. Meiklejohn
Paul T. Meiklejohn, WSBA No. 17477
[email protected]
J. Michael Keyes, WSBA No. 29215

[email protected]


Todd S. Fairchild, WSBA No. 17654

[email protected]


Ryan B. Meyer, WSBA No. 37832

[email protected]


701 Fifth Avenue, Suite 6100

Seattle, WA 98104

Phone: (206) 903-8746 Fax: (206) 299-3594 Attorneys for Defendant Piranha Games Inc.
By s/ Warren J. Rheaume _____
Warren J. Rheaume, WSBA No. 13627 [email protected]

James H. Corning, WSBA No. 45177

[email protected]

1201 Third Avenue, Suite 2200

Seattle, WA 98101

Phone: (206) 757
-8265 Fax: (206) 757-7265
Attorneys for Defendants Harebrained
Schemes LLC, Harebrained Holdings, Inc.,
and Jordan Weisman
Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 11 of 12
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JOINT STATUS REPORT AND
DISCOVERY PLAN
- 12
(NO. 2:17-CV-00327-TSZ)

LAW OFFICES
CALFO EAKES & OSTROVSKY PLLC
1301 SECOND AVENUE, SUITE 2800
SEATTLE, WASHINGTON 98101
TEL (206) 407-2200 FAX (206) 407-2224

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on May
8
, 2017, I electronically filed the foregoing
with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to
the CM/ECF participants.
DATED this
8
th

day of May, 2017.


s/ Mary J. Klemz
Mary J. Klemz



Case 2:17-cv-00327-TSZ Document 32 Filed 05/08/17 Page 12 of 12