Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 144

MOTION for Sanctions [Motion for Enforcement of Court Order, DE#112], by Counter Claimant Forest River Inc. (Attachments: # 1 Affidavit Cert. under Rule 37, L.R. 37.1, # 2 Exhibit A - Poche and Brady emails, # 3 Exhibit B - Fountain email, # 4 Exhibit D - Fountain corresp., # 5 Exhibit E - Donat Dep. Transcript Excerpts)(Fountain, Ryan)

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Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 144 Att. 2 .pear HEARTLAND Dealer: Page 1 of 1 I Jeff Babcock From: Sent: To: Subject: Brad Poche [brad@berrylandcampers.com] Wednesday, 'Tom Kaylor' FW: Message from Brian Brady President & CEO HEARTLAND Recreational Vehicles October 29,20089:28 AM From: Info [mailto:info@heartlandrvs.com] Sent: Tuesday, October 28, 2008 7:36 PM To: brad@berrylandcampers.com Subject: Message from Brian Brady President & CEO HEARTLAND Recreational Vehicles October 28, 2008 Dear HEARTLAND Dealer: As you may be aware, one of our competitors sponsored, I guess you would call it, an open house earlier this week. A number of the dealers attending this function stopped by HEARTLAND as we had a display featuring some new product lines (Le. Eagle Ridge) as well as some new floor plans and some exciting new product features. Our products, which you will see in Louisville along with some really exciting and innovative new "stuff', were exceptionally well received. We signed some new dealers and we wrote a pleasantly surprising and quite frankly, unexpected number of orders. For this the entire . HEARTLAND organization that worked so hard say THANKS. The purpose of this e-mail, however, is not to pitch product. You all get enough of the old GIMME, GIMME, GIMME ·game and HEARTLAND will not add to the crescendo of companies badgering you to order. The purpose of this e-mail is to let. every HEARTLAND dealer know that we understand that it's tough out there. HEARTLAND hears you and we get it. We also want you to understand that HEARTLAND is doing everything conceivably possible (within the limits of good, common business sense) to help whenever and wherever we can. I had the opportunity to speak with a reasonably large number of dealers over the past several days and, as I am sure you can imagine, that is always beneficial. My general takeaway from these conversations would run along these lines: 1. Best product wins. A statement of the obvious, perhaps, but in this challenging environment buyers are really doing their homework and making very well informed decisions. No one can argue that this scrutiny greatly and disproportionately benefits HEARTLAND. There is business out there. People want to buy. Credit availability, as we all know, is a real impediment right now. We also know that this condition will not last forever. When credit conditions improve, and it will, pent up demand will be released. Dealers that have positioned themselves wisely will win and win big. Some manufacturers are doing massive damage to their brands by flooding the market with inferior product and amplify the problem by inconsistent and irrational discounting. Bottom line: the value of the brand is seriously damaged if not destroyed. You can discount lousy product and, you know what, it's still lousy product. You don't gamble in the stock market, why gamble with your business? to: Dodge the Bullet and Beware of false partners. 2. 3. Hang in there guys and Remember Brian Brady President & CEO HEARTLAND Recreational Vehicles 10/2912008 Dockets.Justia.com

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