Timebase Pty Ltd v. Thomson Corporation, The

Filing 118

MEMORANDUM in Support re 116 MOTION to Compel Responses to Interrogatories 1 and 8 filed by Timebase Pty Ltd. SEALED DOCUMENT RECEIVED IN CLERKS OFFICE ON 2/12/10. (Gasey, Arthur) Modified on 2/12/2010 (akl).

Timebase Pty Ltd v. Thomson Corporation, The

Doc. 118 Att. 29

Exhibit 38

Dockets.Justia.com

Trek Bicycle Corporation's Privilege Log For Public Strategies Materials from Initial Contacts through Filing of Litigation LeMond Cycling, Inc. v. Trek Bicycle Corporation v. Greg LeMond Case No. 08-1010 (United States District Court, District of Minnesota)

2 3 4
5
6

7 8 9
10

11

12
13 14

Entertainment (Stapleton), Trek President (Burke) Burke to Trek General Counsel (Burns) Bums to Litigation Counsel (Weber) 04/02/08- Emails McKinnon to Burke 04/03/08 Burke to Bums Bums to Weber 04/02/08 - Emails Bums to Weber 04/03/08 1 Weber to Burns 1 04/03/08 I Email& I Public Strategies .(Coletti) to Weber; cc: Public Strategies Attachment (Bartlett) 1 04/03/08 1 Emails 1 WebertoBurns Burns to Weber 04/03/08 Email Burns to Weber 04/03/08 Email Weber to Coletti, Bartlett; cc: Burns 04/03/08 Email Weber to Burns I 04/03/08 I Email &. I Weber to Coletti, Bartlett; cc: Bums Attachment 04/03/08 Emails & Coletti to Public Strategies (Hendershot) Attachment Hendershot to Coletti Coletti to Weber; cc: Bums and Public Strategies (Anzzolin) 04/03/08 Email& Weber to Coletti, Bartlett; cc: Bums Attachment 04/03/08 Emails Burns to Coletti, Trek (Wagner); cc: Anzzolin, Weber Coletti to Bums, CoIetti, Wagner; cc: Anzzolin, Weber 04/03/08 Email Burns to Weber 04/03/08 Fax Coletti to Weber Attachment

Further discussions re potential Public Strategies work. Further discussions re potential Public Strategies work.

ACP, WP ACP, WP

I I

I

I

I Draft agreement between Public Strategies and Gass

I Weber Mullins.

I Comments on draft agreement between Public strategies and Gass Weber Mullins. Discussion re hiring Public Strategies. Edits to draft agreement. Meeting with Public Strategies. Background information.

I ACP,WP I I ACP, WP
ACP, WP ACP, WP ACP, WP I ACP,WP ACP, WP

I

Revised agreement between Public Strategies and Gass Weber Mullins. Communication to Trek's Board of Directors. Travel arrangements. Meeting with Public Strategies. Executed agreement between Public Strategies and Gass

ACP, WP ACP, WP ACP, WP ACP, WP

Email
16
17

04/03/08 04/03/08 04/03/08 04/03/08

Emails Email & Attachment Email & Attachment Emails

Coletti to Burke, Burns, Weber; cc: Public Strategies [Hinkle) Coletti to Weber Weber to Coletti; cc: Bums Ninkle to Weber; cc: Coletti Weber to Burns, Coletti, Bartlett; cc: Gass Weber Mullins (Dornbrowicki and Stippich) Weber to Bums Burns to Weber Burke to Bums Bums to Weber Weber to Burns Burns to Weber Coletti to Burke, Bums, Weber; cc: Iiinkle Bums, Trek (Gore), Weber, Coletti, Bartlett, Hinkle, Public Strategies (Seman and Mashek) Seman to multiple recipients Coletti to Weber, Bartlett; cc: Burns Weber to Coletti; cc: Bartlett, Burns Bums to multiple recipients Burns to multiple recipients Hinkle to multiple recipients Bartlett to multiple recipients Seman to Burns, Weber; cc: Hinkle, Graham Seman to multiple recipients

Contact information. Confirming privilege notice.

ACP, WP ACP, WP

I8

I wt Gass Weber Mullins. ih 1 Draft complaint for Trek v. LeMond.

Letter of Understanding re Public Strategies engagement

I

ACP, WP

I ACP,WP
ACP, WP ACP. WP

19
20

04/03/08 - Emails 04/04/08 04/03/08 - Emails 04/04/08 Email & 04/04/08 Attachment
04/04/08

I

Discussion re Letter of Understanding re Public Strategies engagement with Gass Weber Mullins. Discussion re Letter of Understanding re Public Strategies engagement with Gass Weier Mullins.

I

21 22 23 24 25 26 27 28 29 30 31 32 33 34

I Contact information.

I ACP,WP

04/04/08 04/04/08 04/05/08 04/05/08

Email & Attachment Email Email Email Emails

Draft of Company Update. Advice re statement. Advice re statement. Draft of Company Update. Terminology. LeMond appearance. Draft of Company Update. Planning for company update. The Complaint LeMond mailed to Trek in 2004. The Complaint LeMond mailed to Trek in 2004. Agenda for Trek Employee Meetinflews Conference Draft of Company Update and advice for Burke's I presentation.

ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, W P ACP, WP ACP, WP

04/06/08 Undated 04/06/08

Email EmaiI & Attachment Email Burns to Burke; cc: Gore, Trek (Moran), Weber Emails Coletti to Hinkle, Burns, Weber; cc: Bartlett Email Burns to Coletti, Hinkle, Bartlett; cc: Weber Agenda Email & Seman to multiple recipients Attachments

2

3
38

36 37

04/06/08 04/06/08 04/06/08

Email Email Emails

04/07/08

42 4 3

04/07/08 04/07/08

Email & Attachment Email Emails & Attachment

Coletti to Stapleton, Bartlett, Weber Burns to multiple recipients Burns to multiple recipients Coletti to Weber . Weber to Coletti Bums to multiple recipients including Trek (Siefkes) Gore to multiple recipients Mashek to Weber; cc: Coletti, Graham Coletti to Weber Coletti to Mashek Mashek to Hinkle Hinkle to Weber Graham to Burke; cc: multiple recipients Graham to Burke; cc: multiple recipients Bums to Graham, Burke; cc: multiple recipients Graham to Weber; cc: multiple recipients Weber to Graham; cc: Dombrowicki Dombrowicki to Graham, Burns; cc: Weber

Discussion about Company Update. Discussion about Company Update. Advice re statement. Trek sales figures. Discussion about Company Update. Press conference call plan. Advice re statement. Draft press release Draft of Burke presentation.

ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP ACP, WP

45

I

04/07/08

I Attachment
I Email &
Attachment

Draft of Burke presentation.
Draft of Burke presentation. Filing of Trek lawsuit.

I

1 Draft agreement between Public Strategies and Gass

Burke to all Trek employees Burns to all Trek employees

Weber Mullins. Draft of Burke presentation. Draft of communication to Trek employees re LeMond. Draft of communication to Trek employees re publicity.

I ACP,WP
ACP, WP ACP, WP ACP, WP

3