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 C

FISH & RICHARDSON P.C.

One Marina Park Drive
Boston, Massachusetts
022IO- I878
Telephone
617 542 -5 0 7 0

Frederick P. Fish
18 55-193 0

w.K. Richardson

BY ELECTRONIC MAIL

Facsimile
617 542 - 89 06

18 59- 195 1

October 17, 2011

Web Site
www.fr.com

Jonathan Zavin, Esq.
Loeb & Loeb LLP
345 Park Avenue
New York, NY 10154-0037
Re:

Jayme Gordon v. DreamWorks Animation SKG, Inc., et al.
USDC-MA - C.A. No. 1:11-cv-l0255-JLT

Dear Mr. Zavin:
ATLANTA

We are in receipt of your letter of today, which you term a response to Mr. Madera's
letter of October 14,2011. However, it is not a response at all.

AUSTIN
BOSTON

You state in your letter that any investigation of Mr. Gordon has been done solely in
connection with his claims and not done with an intention to harass or intimidate.
That representation is simply not true. Your investigators have repeatedly followed
Mr. Gordon, including actually chasing Mr. Gordon in his car on more than one
occasion. Your investigators have also followed Mr. Gordon's wife, son, and his
elderly mother. In addition, your investigators have shown a photograph ofMr.
Gordon to Mr. Gordon's neighbors, implying that Mr. Gordon had done something
improper. These encounters included minor children who were unaccompanied by an
adult. Such actions have no connection to the claims at issue in this case and are
solely designed to harass and intimidate. We intend to bring your activities to the
attention of the Court and seek a protective order and appropriate sanctions.

DALLAS
DELAWARE
HOUSTON
MUNICH
NEW YORK
SILICON VALLEY
SOUTHERN CALIFORNIA
TWIN CITIES
WASHINGTON, DC

Until this issue has been resolved, Mr. Gordon will not be sitting for his deposition,
and will therefore not be appearing on Wednesday.
r

Very truly yours,

fl .

~'Z"zL

P Gr;~ory A. Madera
Juanita Brooks
GAM/kal

Cc: Julia Huston, Esq.