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.\‘1‘T¤RNEvs AT LAW
DAVlD A. BALL
Please Reply To Bridgeport
E-mail: dba||@¤¤hB¤ar1dw0If¤¤m
May 24, 2004
Via Facsimile · 368-0663
and U.S. Mail
Francis D. Burke, Esq.
Mangines & Mangines
11l5 Main Street
Suite 708
Bridgeport, CT 06604
Re: _Q_'Keefe & Associates, Inc. v. Theme Co-Op Promotions, Inc.
Dear Frank:
I enclose documents relating to Jeannine Salveson. The reason that these documents
were not produced previously was a bit of confusion caused by your requesting documents
relating to "Janine Gaivesorf'. Once I realized who was the actual person that was the subject of
your request, I was able to obtain the enclosed documents.
I will be happy to arrange times for Mr. Col1an's deposition, if you tell me when you
would like to depose him. He is situated in California. Mr. Sjoberg is no longer employed at
Theme, and therefore 1 cannot set up a deposition for him. As you know, 1 have also been
waiting for months for you to provide me with deposition dates for Mr- Wallace. I suggest that
we coordinate the Cohan and Wallace depositions at the same time,.
My copies of Bates nos. 1997 and 2354 are the same as yours. I will try to get cleaner
copies, or the originals.
I ain in the process of working to get you the outstanding interrogatory responses. As for
the production requests that you‘ve identified, if we haven't produced documents, it is because
there are no responsive documents.
1115 Baonn Smear 158 Dean Hitt. Avenue 190 Main Smear 112 Paosrsrrr Smear
RD Box 1821 Daursurw, CY 06810 Wssrvoirr. CT 06880 S‘rAM1=orzn. CT 06904
Bmeosvoar. CT 06601-132t Tra: (203) 792-2711 Ter.: (203) 222-t034 Tea.: (203) 964-9907
ra; oem its-can Fax: com nt-sms Fax: ran; svsssot
stx; can set-smut
Case 3:00-cv—00678-SRU Document 57-2 Filed 06/14/2004 Page 2 of 3
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Your client was to provide to me copies of testing results for the subject employees that
have not been provided to date. Although your client testified that it maintains copies in
electronic form, you have not provided any additional documents. Please let ine know when you
can produce these documents. If` they don't exist, l will assume that no testing was done for
those employees.
Please let me know when you would like to arrange for the depositions of Messrs. Cohan
and Wallace.
Very truly yours,
David A. Ball
DAtB:ke
Enclosures
Case 3:00-cv—00678-SRU Document 57-2 Filed 06/14/2004 Page 3 of 3
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COHEN AND WOLF, P.C.
ATTORNEYS AT LAW
1115 Broad Street
Bridgeport, CT 06604
Telephone (203) 358-02.11
Facsimile (203) 576-8504
FAX COVER SHEET
i TO: Francis D. Burke, Esq. {
I FAX NO": (203) 368-0663
FROM: David A. Ball, Esq.
i DATE: May 24, 2004 i
i MESSAGE: X
You will receive 3 pages, including this cover sheet.
If you do not receive ai! 3 pages, please oall David Ball at (203) 337-4134.
FILE NO.: 276030-001
The infomation contained in this commtmioetion is iegaily privileged and,/or coniidential
information which is intended only for use ofthe individual or entity named above. Ifthe reader
of this communication is not the intended recipient (or the agent or employee responsible to
deiiver it to the intended recipient), you are hereby notified that any dissemination, distribution,
or reproduction of this cornniunieatiorz is strictly prohibited. if you have received this
communication in eiror, please immectiately notify us by telephone and return the original
communication to us et the address set forth above via the U.S. Postal Service.
Thani: you.
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