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`ESTTA Tracking number:
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`ESTTA930267
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`Filing date:
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`10/23/2018
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding
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`91241548
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`Party
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`Correspondence
`Address
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`Plaintiff
`Advance Magazine Publishers Inc.
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`JORDAN LAVINE
`FLASTER GREENBERG PC
`1835 MARKET ST, , STE 1050
`PHILADELPHIA, PA 19103
`UNITED STATES
`jordan.lavine@flastergreenberg.com, alexis.arena@flastergreeberg.com, eric-
`clendening@flastergreenberg.com
`215-279-9389
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`Submission
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`Filer's Name
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`Filer's email
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`Signature
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`Date
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`Reply in Support of Motion
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`Alexis Arena, Attorney for Opposer
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`alexis.arena@flastergreenberg.com
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`/Alexis Arena/
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`10/23/2018
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`Attachments
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`Reply Konrad.pdf(209734 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Advance Magazine Publishers, Inc., :
`Opposer,
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`:
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`:
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`v.
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`Konrad Suszczynski-Rodriguez,
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`Applicant.
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`:
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`Opposition No. 91241548
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`
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`REPLY IN SUPPORT OF OPPOSER’S MOTION TO COMPEL
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`Advance Magazine Publishers, Inc. (“Opposer”) files this brief reply to address the new
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`points raised in Applicant Konrad Suszczynski-Rodriguez’s (“Applicant”) Response to
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`Opposer’s Motion to Compel.
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`Applicant attaches his discovery requests to Opposer, but those discovery requests are
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`irrelevant to the pending Motion. As Applicant noted in his Response, Opposer’s responses to
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`his discovery requests were due on October 12, 2018. On October 12, 2018, Opposer sent
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`complete discovery responses and documents to Applicant, and Opposer has not heard anything
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`further from Applicant since that date. This pending Motion only concerns Applicant’s
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`discovery responses.
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`Applicant has provided no further information or supplemented his responses to contain
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`more than boilerplate objections since this Motion to Compel was filed. Although Applicant
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`complains that Opposer’s last email was sent to only one of his email addresses, Opposer notes
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`that: (1) this is the email address that was designated in Applicant’s entry of appearance form for
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`communications and which Opposer understood to be his primary email address; (2) Opposer
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`simply “replied” to the same email address that Applicant had used to send Opposer an email
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`earlier on the same day; and (3) Applicant already had notice that his responses were extremely
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`6943104 v1
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`deficient, as set forth in the earlier emails from Opposer. As set forth in these earlier emails
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`attached to Opposer’s Motion, Applicant was already aware that more than boilerplate objections
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`is required to respond to Interrogatories, Document Requests, and Requests for Admission.
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`CONCLUSION
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`For the reasons stated herein and in Opposer’s Motion to Compel, the Board should order
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`Applicant to fully respond to Opposer’s Requests served on September 16, 2018.
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`Dated: October 23, 2018
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`Respectfully submitted,
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`/s/ Alexis Arena
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`Jordan A. LaVine
`Alexis Arena
`Eric Clendening
`FLASTER/GREENBERG P.C.
`1835 Market Street, Suite 1050
`Philadelphia, PA 19103
`Tel: (215) 279-9389
`Fax: (215) 279-9394
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`ATTORNEYS FOR OPPOSER
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`6943104 v1
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`2
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`Certificate of Service
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`I hereby certify that Advance Magazine Publishers, Inc.’s Motion to Compel
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`was served by email on Applicant as follows:
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`
`Konrad Suszczynski-Rodriguez
`CEO
`Beverage City Polska Sp z o.o.
`1C Lindego St. 30-148 Cracow, Poland
`NIP 6772414696 REGON 366553770 KRS 0000663442
`konrad.suszczynski@beverage-city.com
`info@mapasl.com
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`Dated: October 23, 2018
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`6943104 v1
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`3
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