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 B

Aileen Kelley
From: Huston, Julia [mailto:[e-mail]]
Sent: Tuesday, March 29, 2011 11:14 AM
To: Gregory Madera; [e-mail]
Cc: Joel Leviton; Kristen McCallion; 'Jonathan Zavin Esq. ([e-mail])'
Subject: DreamWorks PowerPoint Presentation dated March 29, 2011
Dear Greg and Mark,
Thank you for meeting with Chris Miller, Jonathan Zavin, and me earlier today. You requested a copy of the PowerPoint
presentation that we made at the meeting. We will deliver to you five hard copies, provided that you agree to abide by the
following restrictions:
1. The PowerPoint is provided as part of settlement discussions subject to F.R.E. 408.
2. The PowerPoint may not be copied or scanned.
3. The PowerPoint may not be shown to anyone except (1) your colleagues at Fish & Richardson and Duane Morris who
are involved in this case or who are evaluating your firms' roles in this case; and (2) your client Jayme Gordon. No copies
may be provided to these individuals. For the avoidance of doubt, Mr. Gordon may see the PowerPoint at your offices,
but may not take possession of the PowerPoint and may not make a copy for himself.
4. You will otherwise treat the PowerPoint as confidential and refrain from disclosing its contents except as set forth
above. You are not required to maintain as confidential any information or documents that were publicly filed in the Dunn
case.
5. At the time that the complaint is either withdrawn or responded to by DreamWorks, or earlier if we so request, you will
return all five copies of the PowerPoint to us.
Please let me know if you have any questions. Otherwise, if you are in agreement, please signal your assent by return
email and we will deliver the five copies promptly.

Regards,
Julia

Julia Huston | Partner
FOLEY HOAG LLP
Seaport West
155 Seaport Boulevard
Boston, Massachusetts 02210-2600
617 832 1166 phone
617 832 7000 fax
www.foleyhoag.com

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