Marolda et al v. Frey et al

Filing 54

DECLARATION of Evan J. Smith, Esquire in Support re: (35 in 1:06-cv-00693-RJH, 32 in 1:06-cv-05402-RJH, 32 in 1:06-cv-04645-RJH, 42 in 1:06-md-01771-RJH, 34 in 1:06-cv-01167-RJH, 33 in 1:06-cv-04643-RJH, 32 in 1:06-cv-04648-RJH, 32 in 1:06-cv-04644-RJH, 32 in 1:06-cv-04647-RJH, 32 in 1:06-cv-04646-RJH, 42 in 1:06-cv-00669-RJH, 32 in 1:06-cv-04642-RJH) MOTION to Approve Preliminarily a Class Action Settlement, Certification of Settlement Class, and Notice Plan.. Document filed by "A Million Little Pieces" Plaintiffs' Group. (Attachments: # 1 Exhibit A# 2 Exhibit B)Filed In Associated Cases: 1:06-md-01771-RJH et al.(Smith, Evan)

Marolda et al v. Frey et al

Case 1:06-cv-01167-RJH

Document 54-2

Filed 04/30/2007

Dc Page 1 ofo2 . 54 Att. 1 Page 1 of 2

Evan J. Smith
From: Sent: To: Cc: September Wynne (Legal) [[e-mail]] Friday, April 27, 2007 9:10 AM Evan J. Smith [e-mail]; Andolina, Michael C.; Blocker, Mark B.; [e-mail]; [e-mail]

Subject: RE: A Million Little Pieces Class Action Litigation Evan: Just a quick follow up to the letter I sent, I had asked IT to do some preliminary analysis on the Million Little Pieces purchases, and they just finished that process. Based on some preliminary analysis, they estimate about 45% of purchases were made via credit card (AND, confirmed that we would have to request contact info from the credit card companies). The remaining estimated 55% of purchases would be untraceable to a distinct customer. They've estimated between 250 and 300 hours to pull the data and associate credit card information through our systems. When you factor in the IT salaries of (on average) between $20-$30/hour that could potentially cost upwards of $10,000, just for the analysis.

September Wynne, ARM Risk Manager & Associate General Counsel Borders Group, Inc. 100 Phoenix Drive Ann Arbor, Michigan 48108 [e-mail] Phone: [phone] Fax: [phone]

-----Original Message----From: September Wynne (Legal) Sent: Wednesday, April 25, 2007 2:49 PM To: 'Evan J. Smith' Cc: [e-mail]; 'Andolina, Michael C.'; 'Blocker, Mark B.'; [e-mail]; '[e-mail]' Subject: RE: A Million Little Pieces Class Action Litigation Evan - attached please find Borders response to your inquiries. Apologize for the delay. Please let me know if you have any further questions. September Wynne, ARM Risk Manager & Associate General Counsel Borders Group, Inc. 100 Phoenix Drive Ann Arbor, Michigan 48108

4/30/2007

Dockets.Justia.com

Case 1:06-cv-01167-RJH

Document 54-2

Filed 04/30/2007

Page 2 of 2 Page 2 of 2

[e-mail] Phone: [phone] Fax: [phone]

-----Original Message----From: Evan J. Smith [mailto:[e-mail]] Sent: Thursday, April 12, 2007 6:12 PM To: September Wynne (Legal) Cc: [e-mail]; 'Andolina, Michael C.'; 'Blocker, Mark B.'; [e-mail] Subject: A Million Little Pieces Class Action Litigation

Dear September, Please see attached correspondence. Thank you for your attention. Evan Smith
Evan J. Smith, Esquire Brodsky & Smith, LLC Two Bala Plaza, Suite 602 Bala Cynwyd, PA 19004 610.667.6200 610.667.9029 (fax) www.brodsky-smith.com

4/30/2007