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)

EXHIBIT A

Aileen Kelley
From: Jonathan Zavin [mailto:[e-mail]]
Sent: Friday, March 04, 2011 3:33 PM
To: Fischer, Mark A.
Cc: [e-mail]
Subject: Gordon v. DreamWorks
Mark,
It was a pleasure to talk to you again. Confirming our conversation, Julia and I are representing the defendants in this
case, and we requested a 30 day extension to answer or move with respect to the complaint. We also suggested that it
might be useful to have an early meeting with you and Greg (and your client if you wish), to explain to you the background
of the creation of Kung Fu Panda, and show you some of the evidence regarding independent creation. As I told you in
our conversation, the purpose of this meeting would not be to "settle" the case, since DreamWorks is not willing to pay
anything on this claim. Rather, we would be willing to show you some of the evidence so that you and your client could
consider whether this is a case that is worth pursuing, considering the time and expense that it will entail. Dates that work
for us for this proposed meeting (in this order of preference) are March 24, 29 , 31 or 30, with the first two being
considerably easier. At the meeting, in addition to Julia and me, an in-house lawyer from DreamWorks would be
present. Please let me know at your earliest convenience about the extension, and the meeting. I look forward to seeing
you, one way or the other on this case.
Jonathan
Jonathan Zavin, Esq.
Loeb & Loeb LLP
345 Park Avenue
New York, NY 10154
E-mail: [e-mail]
NY Tel: [phone]
LA Tel: [phone]
Direct Fax: [phone]

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