Eight Mile Style, LLC et al v. Apple Computer, Incorporated

Filing 134

RESPONSE to 128 MOTION for Order to Exclude Plaintiffs' Late-Disclosed Claim of Entitlement to Profits from Sales of iPods by Apple Inc. Under FRCP 37, Settled Copyright Law, and FRE 702 filed by Eight Mile Style, LLC, Martin Affiliated, LLC. (Attachments: # 1 Index of Exhibits, # 2 Exhibit Declaration of Marc Guilford, # 3 Exhibit Exhibit A, # 4 Exhibit Exhibit B, # 5 Exhibit Exhibit C, # 6 Exhibit Exhibit D, # 7 Exhibit Exhibit E, # 8 Exhibit Exhibit F) (Busch, Richard)

DECLARATION OF MARC R. GUILFORD

EXHIBIT E

Case No. 2:07-cv-13164: Eight Mile Style, LLC, et al. v. Apple Computer, Inc., et al.

Page 1 of 1

Linda Ryman
From: Sent: To: Cc: Marc Guilford Friday, April 24, 2009 3:41 PM Pomerantz, Glenn; Klaus, Kelly; LeMoine, Melinda Richard Busch; Howard Hertz

Subject: 8 Mile outstanding discovery Counsel,

As you are well aware, the deadline for responding to all outstanding written discovery requests is Friday, May 8. We assume you will be responding not only to our second sets of interrogatories and document requests, but also to those portions of the first sets Defendants objected to as "untimely," particularly questions relating to damages and other financial information. If you are not planning to respond to these items from the first interrogatories and document requests, please advise us immediately so we can address it with the Court as soon as possible.
Marc R. Guilford King & Ballow 315 Union Street, Suite 1100 Nashville, TN 37201 Phone: [phone] Fax: [phone]

9/3/2009