Blaszkowski et al v. Mars Inc. et al
RESPONSE in Opposition re 484 Plaintiff's MOTION for Leave to File Supplement to Motion to Add and/or Substitute Arna Cortazzo as a Plaintiff/Class Representative filed by Natura Pet Products, Inc.. (Attachments: # 1 Declaration of Kristen E. Caverly, # 2 Exhibit A to Declaration of Kristen E. Caverly, # 3 Exhibit B to Declaration of Kristen E. Caverly)(Giel, Michael)
SEPTEMBER 12, 2008, EMAIL FROM CATHERINE MACIVOR
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From: Sent: To: Catherine J. MacIvor [CMacIvor@mflegal.com] Friday, September 12, 2008 3:17 PM Kristen Caverly
Subject: Blaszkowski - Davis Declaration
Kristen, I was not able to participate in the telephone conference today, but Jeffrey Maltzman advised that you claim that Ms. Davis' allegedly waived the attorney client privileged in her recent declaration and have asked if we will show you a document indicating that Ms. Davis advised us that she used Natura pet food. First, there was no waiver of the attorney client privilege and I certainly am not willing to show you any attorney client privileged and work product protected document. However, if you determine to forge ahead with more of these baseless allegations concerning Ms. Davis or the Plaintiffs' counsel, I am prepared to show the Court in camera a document dated January 16, 2008 that indicates that Pat Davis had used Natura Innova. I hope we can soon move on to the substantive issues in this case. Regards, Cathy CATHERINE J. MACIVOR
Maltzman Foreman, PA 2 South Biscayne Boulevard Suite 2300 Miami, Florida 33131 Tel : (305) 358-6555 Fax: (305) 374-9077 Email: CMacIvor@mflegal.com
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