Blaszkowski et al v. Mars Inc. et al

Filing 428

MOTION to Compel the Depositions of Plaintiffs and Incorporated Memorandum of Law by Mars Petcare US, Inc., Mars Inc.. Responses due by 8/7/2008 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X)(Ortega, Omar)

Blaszkowski et al v. Mars Inc. et al

Doc. 428 Att. 15

EXHIBIT O

Dockets.Justia.com

Lund, Juli
From: Sent: To: Subject: Lund, Juli Friday, June 20, 2008 2:15 PM '[e-mail]' Re: Blaszkowski - extension request

Cathy, I will find the proposed stipulation and forward it to you. In terms of the extension, I am authorized to agree to an extension of discovery responses until June 30 on the following conditions: (1) you provide whatever veterinarian names and records you have already gathered on Monday, and (2) you provide the purchase locations for the pet food and snacks bought by Kotzampaltiris, Hopkins-Jones, Gaglione and Lucarelli by Monday. If that is acceptable with you, please confirm. Thanks! Juli Ann Lund Williams & Connolly LLP 725 Twelfth Street NW Washington, DC 20005 [phone] [e-mail] ----- Original Message ----From: Catherine J. MacIvor <[e-mail]> To: Lund, Juli Sent: Fri Jun 20 14:00:27 2008 Subject: RE: Blaszkowski - extension request Juli, I have been pretty sick so no. to revert by Monday. May I ask you to forward that to me and I will do my best

Catherine J. MacIvor Partner Maltzman Foreman, PA 2 South Biscayne Boulevard Suite 2300 Miami, Florida 33131 Tel : [phone] Fax: [phone] Email: [e-mail] The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this message in error, please contact the sender and delete the material from any computer. Under applicable U.S. Treasury Regulations, we are required to inform you that any advice contained in this electronic mail message (or any attachment hereto) is not intended to be used, and cannot be used, to avoid tax penalties imposed under the Internal Revenue Code. -----Original Message----From: Lund, Juli [mailto:[e-mail]] Sent: Friday, June 20, 2008 1:58 PM To: Catherine J. MacIvor Subject: Re: Blaszkowski - extension request
1

I am working on obtaining consensus and will get back to you soon. Also, have you had a chance to review the deposition stipulation? We'd like to start planning internally for travel, etc. Thanks! Juli Ann Lund Williams & Connolly LLP 725 Twelfth Street NW Washington, DC 20005 [phone] [e-mail] ----- Original Message ----From: Catherine J. MacIvor <[e-mail]> To: Lund, Juli Cc: Sechler, Phil Sent: Fri Jun 20 13:42:59 2008 Subject: RE: Blaszkowski - extension request Any news on the enlargement? Please advise. If I do not receive it, I will have to move the Court.

Catherine J. MacIvor Partner Maltzman Foreman, PA 2 South Biscayne Boulevard Suite 2300 Miami, Florida 33131 Tel : [phone] Fax: [phone] Email: [e-mail] The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this message in error, please contact the sender and delete the material from any computer. Under applicable U.S. Treasury Regulations, we are required to inform you that any advice contained in this electronic mail message (or any attachment hereto) is not intended to be used, and cannot be used, to avoid tax penalties imposed under the Internal Revenue Code. -----Original Message----From: Lund, Juli [mailto:[e-mail]] Sent: Thursday, June 19, 2008 4:27 PM To: Catherine J. MacIvor Cc: Russell Keith Subject: RE: Blaszkowski - extension request Thanks, Cathy. I have passed that proposal on to the other defendants and will let you know as soon as I hear back. Juli ________________________________ From: Catherine J. MacIvor [mailto:[e-mail]] Sent: Thu 6/19/2008 3:41 PM To: Lund, Juli Cc: Russell Keith Subject: RE: Blaszkowski - extension request
2

Hi Juli, I can provide the locations that plaintiffs Kotzampaltiris, Hopkins-Jones, Gaglione and Lucarelli purchased the pet food or treats at issue here, in addition to the veterinarian records that I have collected and the names of the veterinarians for aforementioned Plaintiffs on Monday. Thanks for your professional courtesy.

Catherine J. MacIvor Partner Maltzman Foreman, PA 2 South Biscayne Boulevard Suite 2300 Miami, Florida 33131 Tel : [phone] Fax: [phone] Email: [e-mail] The information transmitted herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this message in error, please contact the sender and delete the material from any computer. Under applicable U.S. Treasury Regulations, we are required to inform you that any advice contained in this electronic mail message (or any attachment hereto) is not intended to be used, and cannot be used, to avoid tax penalties imposed under the Internal Revenue Code. -----Original Message----From: Lund, Juli [mailto:[e-mail]] Sent: Thursday, June 19, 2008 3:22 PM To: Catherine J. MacIvor Subject: Blaszkowski - extension request Cathy, Phil Sechler is out of the office this afternoon, but asked me to update you with regard to plaintiffs' request for an extension as to discovery. We forwarded your request to the other defendants for consideration, and currently, the defendants appear amenable to an extension until June 30 for plaintiffs' discovery responses if you can agree to provide on Monday the locations that plaintiffs purchased the pet food or treats at issue here, in addition to the veterinarian records you have already collected and the names of the veterinarians for the first group of plaintiffs to be deposed. Can you please let me know whether that agreement is acceptable to you so I can let the other defendants know? I will plan to let you know by COB tomorrow (or sooner, if I hear back from all defendants before then) what the decision is with regard to the extension. Thank you. Juli Ann Lund Williams & Connolly LLP 725 Twelfth Street N.W. Washington, D.C. 20005 [phone] [phone] (facsimile)

----------------------------------------------------------------------------3

NOTICE: This message is intended for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by reply or by telephone (call us collect at [phone]) and immediately delete this message and all its attachments. ======================================================================== ======

4