Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 56

REPLY to Response to 34 Emergency MOTION for Protective Order and Sanctions filed by Jayme Gordon. (Attachments: # 1 Martinez Declaration, # 2 Exhibit A to Martinez Decl, # 3 McCallion Declaration, # 4 Exhibit A to McCallion Decl, # 5 Exhibit B to McCallion Decl, # 6 Exhibit C to McCallion Decl, # 7 Exhibit D to McCallion Decl, # 8 Exhibit E to McCallion Decl, # 9 Exhibit F to McCallion Decl)(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]

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain
confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended
recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this
transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy
the original transmission and its attachments without reading or saving in any manner. Thank you, Loeb & Loeb LLP.

1