LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filing 148

Second Declaration of Jennifer M. Robbins in Support of 114 MOTION for Summary Judgment filed by Greg LeMond, LeMond Cycling, Inc.. (Attachments: # 1 Exhibit(s) 77, # 2 Placeholder for Exhibits 78, 85 and 86, # 3 Exhibit(s) 79, # 4 Exhibit(s) 80, # 5 Exhibit(s) 81, # 6 Exhibit(s) 82, # 7 Exhibit(s) 83, # 8 Exhibit(s) 84)(Robbins, Jennifer) SEALED DOCUMENTS RECEIVED IN CLERKS OFFICE on 8/13/2009 (lph).

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LeMond Cycling, Inc. v. Trek Bicycle Corporation Doc. 148 Case 0:08-cv-01010-RHK-JSM Document 148 Filed 08/13/09 Page 1 of 3 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA LeMond Cycling, Inc., Plaintiff, v. Trek Bicycle Corporation, Defendant/Third-Party Plaintiff, v. Greg LeMond, Third-Party Defendant. Civil No. 08-1010 (RHK-JSM) Judge Richard H. Kyle Magistrate Judge Janie S. Mayeron SECOND DECLARATION OF JENNIFER M. ROBBINS IN SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT I, Jennifer M. Robbins, hereby declare as follows: 1. I am one of the attorneys representing Plaintiff LeMond Cycling, I make this Inc. and Third-Party Defendant Greg LeMond in this case. declaration in support of Plaintiff's Motion for Summary Judgment. 2. Attached to this Declaration as Exhibit 77 is a true and correct copy of a letter from Jennifer M. Robbins of Robins, Kaplan, Miller & Ciresi L.L.P. to Trek counsel dated April 7, 2009. 80960061.1 Dockets.Justia.com Case 0:08-cv-01010-RHK-JSM Document 148 Filed 08/13/09 Page 2 of 3 3. Attached to this Declaration as Exhibit 78 is a true and correct copy of the relevant pages of the deposition transcript of Greg LeMond. 4. Attached to this Declaration as Exhibit 79 is a true and correct copy of the relevant pages of the deposition transcript of Warren Gibson. 5. Attached to this Declaration as Exhibit 80 is a true and correct copy of the relevant pages of the deposition transcript of Thomas Fox. 6. Attached to this Declaration as Exhibit 81 is a true and correct copy of the relevant pages of the deposition transcript of John R. Nevin. 7. Attached to this Declaration as Exhibit 82 is a true and correct copy of the relevant pages of the deposition of John Burke. 8. Attached to this Declaration as Exhibit 83 is a true and correct copy of the relevant pages of the deposition transcript of Ira Langer. 9. Attached to this Declaration as Exhibit 84 is a true and correct copy of Nader v. ABC Television, Inc., No. 04-5034-CV, 2005 WL 2404546 (2d Cir. Sept. 30, 2005). 10. Attached to this Declaration as Exhibit 85 is a true and correct copy of Exhibits 128, 129, 130, and 131 from the deposition of Warren Gibson. 11. Attached to this Declaration as Exhibit 86 is a true and correct copy of correspondence between Sidney Bluming and Bob Burns from July, 1999. 2 80960061.1 Case 0:08-cv-01010-RHK-JSM Document 148 Filed 08/13/09 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Executed this 13th day of August, 2009. /s/ Jennifer M. Robbins Jennifer M. Robbins 3 80960061.1

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