Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 30

NOTICE by DreamWorks Animation LLC, DreamWorks Animation SKG, Inc., Paramount Pictures Corporation DEFENDANTS' LIST OF PROPOSED DEPONENTS (Kluft, David)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

JAYME GORDON,
Plaintiff,
v.
DREAMWORKS ANIMATION SKG,
INC., DREAMWORKS ANIMATION
LLC, and PARAMOUNT PICTURES
CORP.,
Defendants.

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Civil Action No. 1:11-cv-10255-JLT

DEFENDANTS’ LIST OF PROPOSED DEPONENTS
DreamWorks Animation SKG, Inc., DreamWorks Animation LLC, and Paramount
Pictures Corporation (collectively “DreamWorks”) present the following lists of proposed
depositions pursuant to the Court’s Modified Discovery Order.
1. Jayme Gordon;
2. The Jayme Gordon Company 30(b)(6);
3. Small World Enterprises 30(b)(6);
4. Ken Partello;
5. Diane Koro;
6. DreamWorks also seeks to preserve the right to depose:
a.

Any individual who is hereafter identified as having participated in, or has
knowledge of, the creation, development or dissemination of the work (or works)
to Defendants that Jayme Gordon alleges are infringed in this action, or who
worked with Jayme Gordon during the time period in which the work (or works)
are alleged to have been created (potentially including but not limited to Trish
Boyden, Irvin Gallop and Denise Gorham);

b.

Any individual Jayme Gordon proposes to present as a witness at trial, including
but not limited to those individuals who provided the signed statements in support
of Mr. Gordon’s case and that Mr. Gordon produced at JG001651-8 (potentially
including but not limited to Cindy Savage, Derek Tuttle, Daime Gordon, David
Gordon and Jackie Gordon);

c.

Expert witnesses for Jayme Gordon.

Respectfully submitted,
DREAMWORKS ANIMATION SKG, INC.,
DREAMWORKS ANIMATION, LLC, and
PARAMOUNT PICTURES CORP.,
By their attorneys,
/s/ David A. Kluft
John A. Shope (BBO #562056)
Julia Huston (BBO #562160)
David A. Kluft (BBO# 658970)
FOLEY HOAG LLP
Seaport West
155 Seaport Boulevard
Boston, Massachusetts 02210-2600
Telephone: [phone]
Facsimile: 617.832.7000
[e-mail]
[e-mail]
[e-mail]
Jonathan Zavin, pro hac vice
LOEB & LOEB LLP
345 Park Avenue
New York, New York 10154
Telephone: [phone]
Facsimile: 212.658.9105
David Grossman, pro hac vice
LOEB & LOEB LLP
10100 Santa Monica Blvd., Suite 2200
Los Angeles, California 90067
Telephone: [phone]
Facsimile: 310.282.2200
June 30, 2011
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CERTIFICATE OF SERVICE
I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and copies will be sent to those indicated as non-registered participants on the above date.
/s/ David A. Kluft

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B3892936.2