Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 50

MOTION for Leave to File A REPLY MEMORANDUM OF LAW IN SUPPORT OF HIS EMERGENCY MOTION FOR A PROTECTIVE ORDER AND SANCTIONS by Jayme Gordon. (Attachments: # 1 Memo of Law in support, # 2 Martinez declaration, # 3 Exhibit A-Martinez declaration, # 4 McCallion declaration, # 5 Exhibit A-McCallion declaration, # 6 Exhibit B-McCallion declaration, # 7 Exhibit C-McCallion declaration, # 8 Exhibit D-McCallion declaration, # 9 Exhibit E-McCallion declaration, # 10 Exhibit F-McCallion declaration)(Madera, Gregory)

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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 as follows: 1. I am an attorney at Fish & Richardson P.C., counsel of record for Plaintiff, Jayme Gordon, in this action. I am a member of the Bar of the State of New York. I have personal knowledge of the matters stated in this declaration. 2. Attached as Exhibit A is a true and correct copy of an e-mail from Mr. Zavin dated March 4, 2011. 3. Attached as Exhibit B is a true and correct copy of an e-mail from Ms. Huston dated March 29, 2011. 4. Attached as Exhibit C is a true and correct copy of an e-mail from me dated September 7, 2011. 5. Attached as Exhibit D is a true and correct copy of a letter from Loeb & Loeb, LLP to Fish & Richardson P.C. dated September 8, 2011. 6. Attached as Exhibit E is a true and correct copy of the screen shots produced by DreamWorks in this action as DWA 196877 and 196887. 7. Attached as Exhibit F is a true and correct copy of “Form Letter 8” produced by DreamWorks in this action as DWA 196880. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed at New York, New York, this 10th day of November, 2011. /s/ Kristen McCallion 22738972.doc -2-

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