J.T. Colby & Company, Inc. et al v. Apple, Inc.

Filing 30

DECLARATION of Bonnie L. Jarrett in Opposition re: 27 MOTION for Thomas C. Morrison, Kimo S. Peluso, Nirav S. Shah and Amy T. Sheehan to Withdraw as Attorney.. Document filed by Apple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Cendali, Dale)

EXHIBIT G
Jarrett, Bonnie L.
From:
Sent:
To:
Cc:
Subject:

Jarrett, Bonnie l.
Friday, March 23, 2012 10:44 AM
'[e-mail]': Cendali, Dale: Ray, Claudia
'[e-mail]'; [e-mail]1: 'ASheehan@manattcom';
'[e-mail]'
Re: J.T. Colby & Co., Inc. et al. II. Apple, Inc.

Dear Nicole,
We will inspect Plaintiffs' Shelter Island premises on April 3. Please also send us dates on which we may inspect
Plaintiffs' New York City offices.
With respect to the depositions of Mr. Colby and the 30(b}(6) deposition, we will get back to you soon.
Thank you,
Bonnie
From: German, Nicole [mailto:[e-mail]
Sent: Wednesday, March 21, 2012 10:11 PM
To: Cendali, Dale; Ray, Claudia; Jarrett, Bonnie L.
ee: Peluso, Kimo <[e-mail]>; [e-mail]; Sheehan, Amy <[e-mail]>; Morrison,
Thomas <[e-mail]>
Subject: J.T. Colby & Co., Inc. et al. II. Apple, Inc.
Counsel:
I write to address several outstanding issues raised during our call on Tuesday.
First, with regards to Apple's Notice of Inspection, we intend to formally respond to the Notice with our objections in the
lime provided by the Federal Rules. Subject to our objections, we suggest April 3rd as a tentative date for the inspection
of Plaintiffs Shelter Island property. Should successor counsel not be available on April3rd, we, or successor
counsel, will work with Kirkland to find a mutually agreeable date. Please confirm that April 3rd is convenient for Apple.
Second, with regards to Mr. Colby's deposition, Mr. Colby will appear in his individual capacity and as the corporate
representative for J.Boylston & Compaoy 00 April 26th. Should Apple require additional time to examine Mr. Colby, we
are willing to produce him for an additional day.
Finally, we can confirm that, pursuant to the Court's order, we will be producing Plaintiff's hard drive to Apple on Friday.
We will circulate a letter addressing confidentiality and privilege issues relating to that production this Thursday.
Please let me know if you have aoy questions regarding the above.
Best,
Nicole German
IRS CIRCULAR 230 DISCLOSURE: To comply with requirements imposed by the Department of the Treasury, we inform you that
any U.S. tax advice contained in this communication (including any attachments) is not intended or written by the practitioner to be
used, and thm it cannot be used by any taxpayer, for the purpose of (i) avoiding penalties that may be imposed on the taxpayer, and (ii)
supporting the promotion or marketing of any transactions or matters addressed herein. For information about this legend, go to
http://www.111<.natt.com/Expertise.aspx?id=4870

1