vs.
Nelcela, Inc., an Arizona Corporation;
Len Campagna, an Arizona Resident;
Alec Dollarhide, an Arizona Resident;
Ebocom, Inc., a Delaware Corporation;
POST Integrations, Inc., an Illinois Corporation
>¤< >¤< * *
And related cross and third-party claims.
CIV O2-1954-PHX-MHM
CONSOLIDATED STATEMENT OF FACTS CONTROVERTING NELCELA’S
OMNIBUS STATEMENT OF FACTS IN SUPPORT OF ALL MOTIONS FOR
SUMMARY JUDGMENT
AND
POST, LEXCEL, AND MTSI PARTIES’ STATEMENT OF FACTS IN SUPPORT OF
CONSOLIDATED RESPONSE IN OPPOSITION TO NELCELA’S MOTIONS FOR
SUMMARY JUDGMENT
EXHIBIT 54
E-mail String Between Mary Gerdts and Danielle Huffman
1668808.1
Case 2:O2—cv-01954-IVIHIVI Document 352-74 Filed O4/O5/2006 Page 1 of 2
From: Mary Gerdts [[email protected]]
":=nt: Thursday, January 17, 2002 7:26 PM
I Danielle Huffman
subject: Re: Nelcela Lawsuit
Thanks for all your help. I am happy to write you the check but I have to tigure out tirst which one of
my companies the money has to come hom. My accountant needs to review the entries with regard to
the sotware and he is going to let me know. It will be either MasTri or POST, I am just not sure which
one yet. My accountant is schedule to be here on Feb 4th and we should be able to figure it out then.
Plan on me sending you a check that week. Thanks.
Mary L. Gerdts
POST lntegrations lnc.
73 77 Doubletree Ranch Road EXHIBIT gx,
Suite 200 5
ottsdale. AZ 85258
lice: 480—905—0440 x400 [6/,7/of
Mobile: 602-625-0348
Fax: 480-348-9271
>>> "Danielle .H.uft’nian"
>>> >>>·
Mary.
1 don't know why. but l am having trouble locating the tax from l..en. I have been cleaning out my
otlice. which is much like cleaning out a closet--you make a bigger mess than when you started. l will
keep looking. ln the meantime, I am making arrangements t`or you to get any information you need
directly from our attorney in Scottsdale. l will send you his name and number as soon as l notily him.
tie him your name and let him know it is okay to release information to you or your attorneys.
Also. Bill (our corporate counsel) sent the documents we found during our meeting last month to a copy
service. We are waiting for them to be returned. As soon as we get them back. Bill will contact Ann
and get them out to you.
lt` Ann wants to drati a declaration. that would be great. She can send it to me soon as she is done.
1 know time is of the essence, so l *11 let you know soon as 1 speak to the Arizona Attorney (hopefully
by the end ol" today).
Finally, neither Bill nor Gene think there is any problem with our accepting the tinal payment for the
software. When you send it. please make it out to Mi'l`Sl and send to me at 1805 [EE. Garry Ave.. Ste.
120, Santa Ana, CA 92705.
anks Mary. We'll continue to do what we can to help. so don't hesitate to call.
Case 2:02-cv-01954-MHM Documeht 352-74 Filed 04/05/2006 P@Pag®22tgf 2
Case 2:02-cv-01954-MHM
Document 352-74
Filed 04/05/2006
Page 1 of 2
Case 2:02-cv-01954-MHM
Document 352-74
Filed 04/05/2006
Page 2 of 2
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