Free Motion to Compel - District Court of Delaware - Delaware

Case 1 :06-cv—00029-SLR Document 31-6 Filed 10/10/2006 Page1 013
EXHIBIT D

Case 1 :06-cv—00029-SLR Document 31-6 Filed 10/10/2006 Page 2 of 3
MORRIS, Ntoaoies, ARSHT & TUNNEL;. Liar
1201 Nomsrrz Manner Srusr
P.O. Box I3é7
WILMINGTON, Denawnnu l9899-1347
302 658 9200
302 558 3989 Fax
CURTTS S. Miuxn
302 351 9412
September 28, 2006
VIA HAND-DELIVERY
Kester Crosse, Esquire
i2i¢l King Street
Suite 300
Wilmington, DE 19801
Re: Rimmax Wheels, LLC v. RC Components, Inc.,
C.A. No. 06-029
Dear Kester,
This letter identifies (1) the documents that Marc Mathis testified about during his
deposition and which you agreed to produce, and (2) documents that are responsive to RC
Components, Inc. (“RC") First Request for Production of Documents Directed to Plaintiff
Rimmax Wheels, LLC (the “Requests") but which Piaintiff has not produced. This letter
constitutes RC’s effort to reach agreement with Plaintiff pursuant to Local Rule 7.1.1.
Piease produce the following documents:
l) E~maii or other communication from Charles Skarsaune to Michael
Rivers, Jr. This document is responsive to request number 3(ni) ofthe Requests;
2) The confidentiality agreement with Gailard Industries. This document is
responsive to request numbers 3(e), (gg) and 9 of the Requests;
3) A copy of Plaintiff s provisional patent application for a utility patent on
the spirmers. This document is responsive to request numbers 3(e) and 8 ofthe Requests;
4) A copy of any drawings, specifications, or any other documents that
Messrs. Rivers and Mathis provided to RC Components, Inc. ("RC”) upon their visit to
Kentucky to meet with Mr. Ball. These documents are responsive to request numbers 3(e), (g),
(i), and 8 ofthe Requests; ’

Case 1 :06-cv—00029-SLR Document 31-6 Filed 10/10/2006 Page 3 of 3
Kester Crosse, Esquire
September 28, 2006
Page 2
5) Communication from Jim Cooper to Plaintiff that it could not make
spinners for certain motorcycle models. These documents are responsive to request numbers
3(k), (n), (r), (s), 5, 9, and 12 of the Requests;
6) Plaintiffs tax returns, balance sheets, profit and loss statements, financial
statements, and any other documents showing Plaintiff s financial condition in the years 2002-
2006. These documents are responsive to request numbers 3(X), (cc), (gg) and 9 of the Requests;
and
7) Any documents showing the price at which Plaintiff sold the spinners to
its customers, including, but not limited to, Plaintiffs price list for and any receipts from the sale
of spinners, These documents are responsive to request numbers 3-(x), (cc), (gg), and 9 of the
Requests.
Feel free to call me if you have any questions.
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