Gordon v. Virtumundo Inc et al

Filing 117

DECLARATION of Roger Townsend filed by Defendants Virtumundo Inc, Adknowledge Inc, Scott Lynn re 116 MOTION to Exclude Testimony from Lately Disclosed Witnesses or to Compel Their Depositions (Attachments: # 1 Exhibit A - Letter Dated December 20, 2006 To Plaintiffs' Counsel From Defendants' Counsel# 2 Exhibit B - Email Communication Dated 12/27/2006# 3 Exhibit C - Email Communication Dated 12/28/2006# 4 Exhibit D - Email Communication Dated 2/21/2007# 5 Exhibit E - Letter Dated March 13, 2007 To Plaintiffs' Counsel From Defendants' Counsel# 6 Exhibit F- Email Communication Dated 3/14/2007)(Newman, Derek)

Gordon v. Virtumundo Inc et al

Doc. 117 Att. 5

Case 2:06-cv-00204-JCC

Document 117-6

Filed 03/15/2007

Page 1 of 2

EXHIBIT E
LETTER DATED MARCH 13, 2007 TO PLAINTIFFS' COUNSEL FROM DEFENDANTS' COUNSEL

Dockets.Justia.com

Case 2:06-cv-00204-JCC

Document 117-6

Filed 03/15/2007

Page 2 of 2

505 Fifth Avenue South Suite 610 Seattle, Washington 98104

SENT VIA EMAIL AND FACSIMILE March 13, 2007 Robert J. Siegel i.Justice Law, P.C. 1325 Fourth Avenue, Suite 940 Seattle, WA 98101 Re: Dear Bob: This follows up our conversation from last week regarding depositions in the above referenced matter. Effective today, settlement discussions have officially ended. (See Dkt. # 113). Accordingly, we need to arrange for depositions to be conducted as soon as possible. W e requested the opportunity to depose the seven witnesses advanced in support of your motion for summary judgment. (See Dkt. # 56-62). As you are aware, these witnesses were not disclosed in your initial disclosures. (See Dkt. # 25). Additionally, we request the opportunity to depose your expert witness, Pete Resnick. Mr. Resnick was not disclosed until February 12, 2007. (See Dkt. 105). I look forward to working with you to find a mutually agreeable time and place for the depositions. I can be reached directly at [phone]. Regards, NEW MAN & NEWMAN, ATTORNEYS AT LAW, LLP Gordon v. Virtumundo, Inc., United States District Court, W. Dist. Wa., Case No. CV06-0204JCC

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Roger Townsend