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]] Sunday, June 13, 2010 8:08 PM Halter, Jennifer Colgan Gucci v. Durango - CONFIDENTIAL - #1 of 11 GILT GROUP - ANTHONY BOTTICELLI; Lexter Int Tech Inc. dba Vogueway.com - Adnan Budak; FW: Account Pre-App (Jennifer White); Durango Search Terms.doc

Jennifer: In its continued effort to search all of its records, electronic or otherwise, Durango came across a previously non-reviewed general "customer service box" of e-mail communications regarding merchants and prospective merchants. Specifically, the function of the box is to store leads and first response e-mails for the purpose of determining who is working a lead should a prospective merchant call in (i.e. to insure that the first agent to bring in a particular lead gets proper credit for same). Though this "box" was used for less than two years, it was not deleted in the ordinary course of business for the above reason, especially since any general communications in such box would not have sensitive customer information, i.e. social security numbers, bank account numbers, etc. As such, though its probative value to the litigation is questionable, Durango is herewith producing the relevant contents of the customer service box in good faith, and this is the first of 11 eleven emails containing same, broken up due to file size. Please treat all such documents as CONFIDENTIAL under the Protective Order.

Also attached, per your request, please find a Word file containing the list of search terms used by Durango in this process. Please feel free to reply with any questions- Todd Law Offices of Todd Wengrovsky, PLLC. 285 Southfield Road, Box 585 Calverton, NY 11933 Tel [phone] Fax [phone] [e-mail]

1