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 E

FISH & RICHARDSON P.C.

Telephone

Frederick P. Fish
18 55-193 0

BY'EMAIL

617 542-5 0 7 0

Facsimile

WK. Richardson
18 59- 1951

One Marina Park Drive
Boston, Massachusetts
022IO- I878

October 17, 2011
Mr. Jonathan Zavin
Loeb & Loeb LLP
345 Park Avenue
New York, NY 10154-0037
Re:

617 542- 89 06

Web Site
www.fr.com

Jayme Gordon v. DreamWorks Animation SKG, Inc., et aI., USDC, D. Mass.
C.A. No. 1: ll-cv-l 0255-JL T, USDC-MA - C.A. No.1: ll-cv-l 0255-JL T
"

Dear Mr. Zavin,
ATLANTA
AUSTIN
BOSTON
DALL A S
DELAWARE
HOUSTON
MUNICH
NEW YORK
SILICON VALLEY
SOUTHERN CALIFORNIA
TWIN C ITIES
WASHINGTON, DC

Thank you for your letter, which was received by Mr. Madera via e-mail at 3:40pm
today. As we previously informed you, due to the actions of Defendants and their
age" we eMr. Gordon' s attorneys), are postponing Mr. Gordon's deposition until
nts,
we have been able to obtain a protective order from the Court restraining the activities
of your agents. We are in the process of preparing a motion that we expect to file
shortly:
You now admit that Mr. Gordon has been the subj ect of surveillance and that your
investigators have had discussions with his neighbors . Between Ms. Brooks and I, we
have been practicing law for nearly seventy years, and have never encountered these
tactics in an intellectual property case. The issues in this case concern Defendants'
alleged copying ofMr. Gordon's works. We are at a loss to see how interviewing the
children of Mr. Gordon's neighbors, or the surveillance of Mr. Gordon and his
family; could result in the disclosure of information that would have any relevance to
the issues in this case.
After we have obtained the appropriate protective order from the Court we can
discuss the rescheduling ofMr. Gordon's deposition for a mutually convenient date.
Very truly yours,

j~'rI C . 0lo~
Gregory A. Madera

2~;f&-L
Juanita R. Brooks
cc:

Julia Huston
"

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