Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 34

Emergency MOTION for Protective Order and Sanctions by Jayme Gordon. (Attachments: # 1 Affidavit McCallion declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F-Notice of filing with Clerk's office)(Madera, Gregory)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
JAYME GORDON,
Plaintiff,

C.A. No. 1:11-cv-10255-JLT

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

DECLARATION OF KRISTEN McCALLION

I, Kristen McCallion, declare and state as follows:
1.

I am an attorney at Fish & Richardson P.C. I represent Plaintiff, Jayme Gordon

("Gordon"). I make this declaration of my own knowledge, and could and would testify
competently as to the matters set forth herein if called upon to do so by a court of law.
2.

Attached as Exhibit A is a true and correct copy of a letter dated October 14,

2011, that was sent by Fish & Richardson P.C., to lead counsel for Defendants, Jonathan Zavin
of Loeb & Loeb LLP.
3.

Attached as Exhibit B, is a true and correct copy of a letter dated October 17,

2011, from Jonathan Zavin to Fish & Richardson P.C.
4.

Attached as Exhibit C, is a true and correct copy of a letter dated October 17,

2011, that was sent by Fish & Richardson P.C. to Mr. Zavin.
5.

Attached as Exhibit D, is a true and correct copy of a letter dated October 17,

2011, from Jonathan Zavin to Fish & Richardson P.C.

6.

Attached as Exhibit E, is a true and correct copy of a letter dated October 17,

2011 that was sent by Fish & Richardson P.C. to Mr. Zavin.
7.

As noted in the accompanying memorandum oflaw, Fish & Richardson P.C. is

filing under separate cover as Exhibit F, via hand delivery tomorrow morning, two video
recordings taken by Mr. Gordon of one of Defendants' investigators.

Executed this 18th day of October, 2011 at Boston, Massachusetts.

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