I/P Engine, Inc. v. AOL, Inc. et al

Filing 795

Declaration re 792 MOTION FOR AN AWARD OF PREJUDGMENT INTEREST, POST-JUDGMENT INTEREST, AND SUPPLEMENTAL DAMAGES FOR DEFENDANTS POST-DISCOVERY/PRE-VERDICT INFRINGEMENT of Dawn Rudenko, Esq. by I/P Engine, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Sherwood, Jeffrey)

Exhibit 5

From:

Sent:
To:
Cc:

Subject:

Sarah Agudo <[e-mail]>
Friday, November 09, 2012 3:47 PM
Albert, Dawn Rudenko; Monterio, Charles
QE-IP Engine; 'Stephen E. Noon a ([e-mail])'; zz-IPEngine; 'W. Ryan Snow
([e-mail])'; 'Donald C. Schultz ([e-mail])'
RE: I/P Engine v. AOL et al. Supplemental Interrogatory No. 15

Dawn,
Thank you for sending the decision. Please, however, explain how you intend to use the data you are requesting to
calculate supplemental damages.
We are not available for a meet and confer today, but we are available at 2pm PT on Monday.
Thank you,
Sarah
-----Original Message---From: Albert, Dawn Rudenko [mailto:[e-mail]]
Sent: Friday, November 09, 2012 10:12 AM
To: Sarah Agudo; Monterio, Charles
Cc: QE-IP Engine; 'Stephen E. Noona ([e-mail])'; zz-IPEngine; 'W. Ryan Snow ([e-mail])';
'Donald C. Schultz ([e-mail])'
Subject: RE: 1/P Engine v. AOL et al. Supplemental Interrogatory No. 15
Sarah,
The decision is attached. As the prevailing party, 1/P Engine is entitled to supplemental damages post-discovery/preverdict. I apologize for not sending the decision previously. I assumed counsel would be aware ofthe decision since Mr.
Noona signed and submitted the underlying motion and memoradum of law relating to the same. As this issue has been
outstanding since November 6, 2012, please provide us Defendants' position by 5:0p ET today. Again, if Defendants will
not agree to provide this information, please let me know if you are available to meet and confer today, I suggest 5:00

ET.
Regards,
Dawn Rudenko Albert
Dickstein Shapiro LLP
{212) 277-6715