Gucci America, Inc. v. Frontline Processing Corporation et al

Filing 46

DECLARATION of Jennifer C. Halter in Support re: 45 Memorandum of Law in Support. Document filed by Gucci America, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29)(Weigel, Robert)

Halter, Jennifer Colgan
From: Sent: To: Subject: Attachments: Law Offices Of Todd Wengrovsky, PLLC. [[e-mail]] Friday, June 11, 2010 8:08 PM Halter, Jennifer Colgan Gucci v. Durango - HIGHLY CONFIDENTIAL - 1 of 22 BeanstreamMay 2009.xls; BeanstreamMay2006.xls; BeanstreamMay2007.xls; BeanstreamMay2008.xls; BeanstreamNov2006.xls; BeanstreamNov2008.xls; BeanstreamNov2009.xls; BeanstreamNovember2007.xls; BeanstreamOct2006.xls; BeanstreamOct2007.xls; BeanstreamOct2008.xls; BeanstreamOct2009.xls; BeanstreamSept2006.xls; BeanstreamSept2007.xls; BeanstreamSept2008.xls; BeanstreamSept2009.xls; BeanstreamApril 2009.xls; BeanstreamApril2006.xls; BeanstreamApril2007.xls; BeanstreamApril2008.xls; BeanstreamApril2010.xls; BeanstreamAug2008.xls; BeanstreamAug2009.xls; BeanstreamAugust2006.xls; BeanstreamAugust2007.xls; BeanstreamDec2005.xls; BeanstreamDec2006.xls; BeanstreamDec2007.xls; BeanstreamDec2008.xls; BeanstreamDec2009.xls; BeanstreamFeb 2008.xls; BeanstreamFeb 2009.xls; BeanstreamFeb2006.xls; BeanstreamFeb2007.xls; BeanstreamFeb2010.xls; BeanstreamJan 2008.xls; BeanstreamJan 2009.xls; BeanstreamJan2006.xls; BeanstreamJan2007.xls; BeanstreamJan2010.xls; BeanstreamJuly2006.xls; BeanstreamJuly2007.xls; BeanstreamJuly2008.xls; BeanstreamJuly2009.xls; BeanstreamJune2006.xls; BeanstreamJune2007.xls; BeanstreamJune2008.xls; BeanstreamJune2009.xls; BeanstreamMarch 2008.xls; BeanstreamMarch 2009.xls; BeanstreamMarch2006.xls; BeanstreamMarch2007.xls; BeanstreamMarch2010.xls

Jennifer: Durango is in receipt of your letter of today and, as a show of good faith, is willing to produce all of its available electronic residual reports, even though most of the material is irrelevant to the present litigation. This is the first of 22 e-mails, with each separate e-mail including monthly reports of residuals received by Durango from each individual processor. The e-mails are in alphabetical order of processors, for convenience. Durango demands that the attachments of all 22 related e-mails be treated as HIGHLY CONFIDENTIAL, with the materials available only to counsel and not clients. Durango is continuing its search of records pursuant to your request, and is now using the information from Frontline's recent document production to facilitate same. Specifically, because Durango does not keep application documents (such as those produced by Frontline), it now has additional information (i.e. the names of individual principals) to use in a search. As such, we expect to respond to you with further details prior to the Monday depositionsTodd Law Offices of Todd Wengrovsky, PLLC. 285 Southfield Road, Box 585 Calverton, NY 11933 Tel [phone] Fax [phone] [e-mail]

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