Dish Network Corporation et al v. Ace American Insurance CompanyMOTION for Summary Judgment . DocumentS.D.N.Y.March 18, 2019 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK DISH NETWORK CORPORATION and DISH NETWORK L.L.C. Plaintiffs, v. ACE AMERICAN INSURANCE COMPANY Defendant. : : : : : : : : : : Case No. 1:16-cv-04011-ALC PLAINTIFFS DISH NETWORK CORPORATION AND DISH NETWORK L.L.C. NOTION OF MOTION FOR PARTIAL SUMMARY JUDGMENT To: All Counsel of Record PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 56 and Rule 56.1 of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York, Plaintiffs DISH Network Corporation and DISH Network, L.L.C. (collectively, “DISH”), by and through undersigned counsel, shall move for partial summary judgment on Defendant ACE American Insurance Company’s duty to defend DISH in a series of underlying lawsuits involving the four major broadcast networks, before the Honorable Andrew L. Carter, Jr., Courtroom 1306, at the United States District Court for the Southern District of New York, Thurgood Marshall United States Courthouse, located at 40 Foley Square, New York, NY 10007. The basis and reasoning for partial summary judgment is set forth in DISH’s accompanying memorandum of law in support of its motion, statement of undisputed material facts, and declaration of Lee M. Epstein. PLEASE TAKE FURTHER NOTICE that oral argument is requested. Case 1:16-cv-04011-ALC-GWG Document 154 Filed 03/18/19 Page 1 of 3 -2- Dated: March 18, 2019 Respectfully submitted, /s/ Lee M. Epstein Lee M. Epstein Matthew A. Goldstein (admitted pro hac vice) Weisbrod Matteis & Copley PLLC Two Logan Square, Suite 1925 100 N. 18th Street Philadelphia, PA 19103 (215) 883-7422 lepstein@wmclaw.com mgoldstein@wmclaw.com Case 1:16-cv-04011-ALC-GWG Document 154 Filed 03/18/19 Page 2 of 3 CERTIFICATE OF SERVICE I, Lee Epstein, hereby certify that on March 18, 2019, I electronically filed the foregoing Plaintiffs DISH Network Corporation and DISH Network L.L.C.’s Notion of Motion for Partial Summary Judgment via the Court’s CM/ECF system, which will send notification of such filing to the attorneys of record in this case. Dated: March 18, 2019 /s/ Lee M. Epstein Lee M. Epstein Matthew A. Goldstein (admitted pro hac vice) Weisbrod Matteis & Copley PLLC Two Logan Square, Suite 1925 100 N. 18th Street Philadelphia, PA 19103 (215) 883-7422 lepstein@wmclaw.com mgoldstein@wmclaw.com Case 1:16-cv-04011-ALC-GWG Document 154 Filed 03/18/19 Page 3 of 3