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 B

JONATHAN ZAVIN

Partner
345 Park Avenue
New York, NY 10154

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Via E-mail

October 17, 2011
Gregory A. Madera
Principal
Fish & Richardson P.C.
One Marina Park Drive
Boston, Massachusetts 02210-1878
Re:

Gordon v. DreamWorks Animation SKG

Dear Mr. Madera:
This is in response to your letter to me of October 14,2011 regarding an investigation of Jayme
Gordon in connection with the above-captioned matter.
Mr. Gordon should hardly be surprised that he is being investigated in connection with this
claim. He has falsely accused both a reputable company, and a large number of individuals of
stealing from him, and lying about the creation of Kung Fu Panda, a film that hundreds of people
(but not Mr. Gordon), labored many years to create. Any investigation of Mr. Gordon has been
done solely in connection with his claims, and not done with the intention to either harass or
intimidate him.
Neither DreamWorks or its counsel has requested or authorized any investigator to do anything
illegal, and in your letter you don't claim or even suggest that they have. DreamWorks reserves
its right to take any action it deems appropriate to defend itself from Mr. Gordon's spurious
claims, so long as such action is neither illegal nor improper.
Finally, any reports from any investigation of Mr. Gordon that were done at the direction of
DreamWorks' counsel in connection with this litigation is attorney work product, and is privileged
information that need not be disclosed.
If you have any further questions regarding this matter, please let me know.
Yours truly,

,

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Jonathan Zavin
Partner

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