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)

EXHIBIT A

FISH & RICHARDSON P.C.

O ne Marina Park D ri ve

Boston,

Mas~dlUscm

02210-1878

Frederick 1'. Fish
1855-1930

W.K. Richardwn
1l! 59-195 1

Telephone

October 14, 2011

617 542-5070

VIA EMAIL

Facsi m ile
617 )42-8906

Confirmation by Mail

Jonathan Zavin
Loeb & Loeb
345 Park Avenue
New York, NY 10154
Re:

W eb Site
www.fr. com

Jayme Gordon v. Dream Works Anima/ion SKG, Inc. , el aI. ,

USDC. D. Mass. CA. No. 1:1l·cv· 10255·JLT
Dear Mr. Zavin:
... TL ... NT ...
... USTIN

[)ALl . ... S

DEL ... W ... RE
I!OU~TON

M UNICH

NEW YORK

We have learned that private investigators, including Jim Lane, have been watching
and following Jayme Gordon- and members of his family, including his wife and
son---on numerous occas ions over the last few weeks causing them to become fearful
and distressed. We also understand that investigators have contacted Mr. Gordon ' s
neighbors, including chi ldren, asking questions about Mr. Gordon and showing the
picture ofMr. Gordon that was included in his Complaint against DreamWorks. In
addi tion, a representative of Marcum LLP has called at least one of Mr. Gordon 's
friends seeking information about Mr. Gordon and asking about the case involving
Kung Fu Panda. These facts strongly suggest that DreamWorks or its counsel is
behind these disturbing events.

SILICON V ... L LEY
SOUTHERN C ... LlfORNI ...
TWIN C IT IU
W"'SHIt<CTON, OC

As one might expect, and presumably as intended, these actions are very upsetting to
Mr. Gordon and his family. Because such investigations have no relevance to or
bearing on Mr. Gordon' s copyright infringement claims, we must conclude that thi s is
being done to harass and intimidate our client. We demand that all such
investigations and harassment stop immediately.
Please immediately advise us whether your firm, co-counsel, or DreamWorks have
hired private investigators to investigate Mr. Gordon. lfso, please identify the
investigators that have been hired, describe the steps such investigators have taken
with respect to Mr. Gordon, explain why DreamWorks elected to investigate Mr.
Gordon, and provide us with any reports that have been furnished to you, your cocounsel, or your client from an investigator concerning Mr. Gordon.
Please provide your response as soon as possible and no later than Monday,
October 17.
Very truly yours,

~~C , rfJ~
Gregory A. Madera
cc: Ju lia Huston