LeMond Cycling, Inc. v. Trek Bicycle Corporation

Filing 91

LeMond Cycling, Inc. v. Trek Bicycle Corporation

Doc. 91

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.

Case No. 08-CV-01010 (RHK/JSM)

DECLARATION OF DENISE S. RAHNE IN SUPPORT OF PLAINTIFF'S MOTION FOR ENTRY OF A PROTECTIVE ORDER REGARDING DEFENDANT'S THIRD-PARTY SUBPOENAS Date: February 17, 2009 Time: 11:00 a.m. Judge: Janie S. Mayeron

I, DENISE S. RAHNE, declare and state as follows: 1. I am an attorney representing Plaintiff LeMond Cycling, Inc. and Third-

Party Defendant Greg LeMond (collectively "Plaintiff"). I make this Declaration on personal knowledge and in support of Plaintiff's Motion for Entry of a Protective Order Regarding Defendant's Third-Party Subpoenas. 2. Attached to this Declaration as Exhibit 1 is a true and correct copy of the

Sublicense Agreement between LeMond Cycling, Inc. and Trek Bicycle, Corp., dated June 29, 1995.

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Dockets.Justia.com

3.

Attached to this Declaration as Exhibit 2 is a true and correct copy of

Trek's Subpoena and cover letter to Maslon, Edelman, Borman & Brand LLP, dated December 22, 2008. 4. Attached to this Declaration as Exhibit 3 is a true and correct copy of an

email from Margo Brownell of Maslon, Edelman, Borman & Brand LLP to Denise S. Rahne of Robins, Kaplan, Miller & Ciresi L.L.P., dated January 7, 2009.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 3rd day of February 2009. /s/ Denise S. Rahne Denise S. Rahne

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