Free Motion for Protective Order - District Court of Connecticut - Connecticut

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June 29, 2004
VIA FACSIMILE 203.324.9291
CONFIRMATION VIA U.S. MAIL
Mr. David Poppick, Esq.
Epstein, Becker & Green, P.C. — t
One Landmark Square, 18th Floor
Stamford., CT 06901 · -
Re: Rosemount Aerospace Inc. v. Harco Laboratories, Inc.
Our Reference: 1297l.OOO9USZA 4
Dear David: -
I have talked to I im Rashid about his records and recollections regarding the anonymo
mailing forwarded to Rosemount Aerospace Inc. by Rosemount, Inc. regarding I-Iarco'
misappropriation of drawings and tools from Lewis Engineering and/or Weed Instrum ts-
Mr. Rashid was working for Goodrich in Ohio in June 2000, when the package was
forwarded to Rosemount Aerospace, Inc. He did not receive any original documents in
the package, nor did he receive the envelope in which the original documents were mai ed
to Rosemount Inc. A
As you know, we have withheld the production of some attorney notes related to these
documents on the basis ofwork product immtmity and/or attorney-client privilege.
Nevertheless, my investigation and discussions with Mr. Rashid conisimi our understan ` g
that someone, perhaps Mr. Krouth from Rosemount, Inc., indicated that there was no
address or other originating information provided with the documents or their envelope _
Neither Merchant & Gould nor Mr. Rashid have any record of receiving the envelope, r a
4 photocopy of the envelope. To the contrary, our records indicate that some inquiry w
made to determine the postmark city and state on the envelope, but those efforts did no
result in obtaining any such information.
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Q Dunvcr
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i Atlanta
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Page 2 · 1
I believe that the above, in combination with the documents and letter previously provided
to you, provides all ofthe information we have that is relevant to identifying the source of
the misappropriation documents and their envelope. This should also contirm for you that
no purpose would be served by deposing Mr. Rashid or me about the docu ments or the}
envelope. f
If you have any questions, please let me know. i
Yours truly, ‘
nmtet w. Mcnmm i
DWM/bes _
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