Free Response to Motion - District Court of Arizona - Arizona

EXHIBIT "C"
Case 2:04-cv-00299-DGC Document 457-4 Filed 10/05/2006 Page 1 014

, D LLP \/
ATTORNEYS AT LAW 499 PARK .
NEW YDRK, NEW YCIRK 1D 22
THE GURSKY GRDUP A TEL: (212) 32E·S1UEI
‘ FACSIMILE! (212) 3zB·6 1 D1
wi I 3 l SAFIA ANAND
A Dinzcv DIAL! (212) 552-3'7'73
I [email protected]¤M
_ April 8, 2005
VIA FIRST CLASS MAIL
Clay Townsend, Esq.
. Morgan, Colling & Gilbert, P.A.
2. _;. ,___ . . _. .. ,; _ . _.__. ., , ., . . .. .. . .. ,... ..~ . . . . . A . . -`.,-.,.,..... . _
Orlando, FL 32802
Re: Meadowlark Lemon vs. Harlem Globetrotters Intemational, Inc., Case No.
CV—04-1023-PHX-EHC. Case No. CV—04-0299-PHX-DGC -
Dear Clay: A
_ I write in response to your letter, dated February 16, 2005, requesting clarification
on several ofthe documents that were produced by our clients in this litigation. Please
be advised as follows:
1. I Style H3305 - The player’s rrarne on the Nautical Blue Jersey is
Meadowlark Lemon, the narrre on the True Red Jersey is Marques
Haynes, the name on the Pirate Black Jersey is Curly Neal and the
name on the Bright White Jersey is Geese.
2. H23 l4— We have been unable to find any evidence that the
illustration was meant to depict any ofthe plaintiffs in this action.
3. H23l3 — We have been unable to find any evidence that the
illustration was meant to depict any ofthe plairrtiffs in this action.
4. H230l — The illustration is Curly Neal and it says “Curly"
underneath the illustration.
I 5. H3345 .— Curly Neal appears with the number 27, indicating the
year 1927. “
6. H3352 — We will be sending you bates starrrped copies ofthe sales
Â¥ detail report for this style number, wlriclr do not cut off the color
description column for the Daffodil/Azure Blue color.
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Mr. Clay Townsend
April 8, 2005
Page 2 of 3
7. The Sales Detail Report (By Style) is complete for all of the men’s
and boy’s lines. Moreover, as you are aware, GTPM, LLC did not
‘ produce the women’s line of Globetrotters apparel and therefore is L
not in possession of any Sales Detail Report (by Style) for that
line. GTFM, LLC has produced all the documents in its
possession for the women’s line.
. 8. No summary of styles and sales organized by players’ names
exists.
9. l·l354l —We will be producing a color CAD of this style number
with our next document production.
10. H3335 — The colors and corresponding players for the jerseys in
this CAD are: (i) Turkish Sea/True Red — Meadowlark Lemon; (ii)
Bright White/Med.H.Grey —— Curly Neal, (iii) Daffodil/Pirate Black
· Larry "Gator" Rivers; (iv) Verdent Green/Bright \/Vhite ~ Dallas
"Big D" Thomton; (v) True Red/Mood Indigo ~ James "Twiggy"
Sanders; and (vi) and (vii) Pirate Black/Turkish Sea and Azure
Blue/Azure Blue are Goose and Sweet Lou. We will be producing
a color CAD of this style number with our next document . .
production. T i »
ll. As stated above, no Sales Detail Reports (by Style) exist for the
women’s line. Moreover, GTFM, LLC produced all documents in
L its possession for the women’s line which relate to all of the
plaintiffs in this action. T
l2. We will not review the accuracy of the worksheet you prepared.
As required by the federal rules, we have produced all responsive
documents in our client’s possession. We have no obligation to
review opposing counsel’s work product and continn its accuracy.
Case 2:04-cv-00299-DGC Document 457-4 Filed 10/05/2006 Page 3 of 4 —

Mr. Clay Townsend . I
April 8, 2005 r
Page 3 of 3 _ _
I hope that our responses have been helpful to you. . A _
. Sincerely,
Anand V _
Encl.
cc: Joel Herz, Esq. (via First Class Mail, w/enclosure)
Anders Rosenquist, Jr., Esq. (via First Class Mail, w/enclosure)
Edward R. Garvey, Esq. (via First Class Mail, w/enclosure)
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