Free Response to Motion - District Court of Arizona - Arizona

EXHIBIT "G"
Case 2:04-cv-00299-DGC Document 457-8 Filed 10/05/2006 Page 1 012

Clay Townsend
From: Safia Anand [[email protected]]
Sent: Thursday, September 29, 2005 4:27 PM
To: Clay Townsend
Cc: Vanessa Braeleyg fIorenoe@bruemmeriawcom; [email protected]; Ira Sacks; [email protected]
Subject: RE: Lemon
Clay,
If you send us something that details what you sent us and the date you sent it to us, we
will return the goods to you with a similar document, which will preserve the chain of
custody between your firm and ours. We will also agree not to take the merchandise
outside of our offices. We have done this type of thing numerous times in the past and
the chain of custody between your firm and ours will remain secure.
As for the Phillipines, Ira emailed you on Sept. 19 regarding this issue, but we can
discuss it with the Judge if you prefer.
Safia
————— Original Message ---——
From: Clay Townsend [mailto:[email protected]]
Sent: Thursday, September 29, 2005 3:33 PM
To: Safia Anand
Cc: Vanessa Braeley; '[email protected]'; '[email protected]'
Subject: RE: Lemon
Yes. How do you recommend we do this without hearing about chain of custody issues later?
Maybe you guys should come here as they are secure. We could get judge's input at the
conference today. We are asking for some more limited discovery relative to the
Phillipines issue. Ira emailed saying he was looking into the store and sales but I
didn't hear any more. The investigator produced the garments, receipts and photos at his
depo.
—-—-- Original Message —————
From: Safia Anand [mailto:[email protected]]
Sent: Wednesday, September 28, 2005 10:45 AM
To: Clay Townsend; Heather Fischer
Cc: [email protected]
Subject: Lemon
Clay,
Joel Herz sent us a list of garments that your investigators purchased and
said that you offered to send them to us to photograph. Please send us all
of the garments and include a summary of where they were purchased and by
whom. You can send them to my attention at: Dreier LLP, 1350 Broadway,
11th Floor, NY, NY 10018. Thank you.
Very truly yours,
Safia
Safia A. Anand, Esq.
Dreier LLP
Email: [email protected]
www.dreierllp.com
PRIVILEGED AND CONFIDENTIAL ATTORNEY—CLIENT COMMUNICATION
This transmission is intended only for the use of the addressee and may
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Case 2:04-cv-00299-DGC

Document 457-8

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Case 2:04-cv-00299-DGC

Document 457-8

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