Subject: RE: Customer List
From: <[email-masked]>
To: <[email-masked]>
Cc: <[email-masked]>, <[email-masked]>, <[email-masked]>, <[email-masked]>
Date: Wed, 17 Sep 2008 12:40:35 -0600

Sounds good, thanks David.
 
Have you received copies of the Fatas' deposition transcripts yet?  If
so, will you please send us copies, too.  Thanks.
 
Jeff

________________________________

From: David R. Brake [mailto:[email-masked]] 
Sent: Wednesday, September 17, 2008 8:01 AM
To: Lippa, Jeffrey M. (Assoc-Den-LT)
Cc: Kriss Gillengerten; Mike Bishop
Subject: Re: Customer List

I should be able to email to you today a customer list with the date of
sale and dollar amount.  The refund list is not normally compiled but we
are working on it.
David R. Brake
Knaggs, Harter, Brake and Schneider, P. C.
7521 Westshire Dr. Ste 100
Lansing, MI 48917
Tx (517) 622-0590
Fx (517) 622-8463
[email-masked]

	----- Original Message ----- 
	From: [email-masked] 
	To: [email-masked] 
	Cc: [email-masked] ; [email-masked] 
	Sent: Tuesday, September 16, 2008 7:55 PM
	Subject: RE: Customer List

	David:  
	 
	As you know, the Court ordered this information produced by
tomorrow.  If we don't maintain this information in the normal course of
business, that's one thing -- however, we did not indicate that to the
Court last week.  My overarching concern is aggravating the Judge on the
eve of trial.

	Jeffrey Lippa
	Greenberg Traurig, LLP
	The Tabor Center
	1200 17th Street / Suite 2400 / Denver, CO  80202
	Phone:   303-572-6535
	Email:    [email-masked] <mailto:[email-masked]>
<http://www.gtlaw.com/Home> 

________________________________

	From: David R. Brake [mailto:[email-masked]] 
	Sent: Tuesday, September 16, 2008 3:00 PM
	To: Lippa, Jeffrey M. (Assoc-Den-LT)
	Subject: Re: Customer List

	I'll find out.
	David R. Brake
	Knaggs, Harter, Brake and Schneider, P. C.
	7521 Westshire Dr. Ste 100
	Lansing, MI 48917
	Tx (517) 622-0590
	Fx (517) 622-8463
	[email-masked]

		----- Original Message ----- 
		From: [email-masked] 
		To: [email-masked] 
		Sent: Tuesday, September 16, 2008 3:51 PM
		Subject: RE: Customer List

		Do we have a list that includes the additional
information the AG seeks, i.e., order info. (date, amount, etc) and
return info?

________________________________

		From: David R. Brake [mailto:[email-masked]] 
		Sent: Tuesday, September 16, 2008 1:13 PM
		To: Lippa, Jeffrey M. (Assoc-Den-LT)
		Subject: Re: Customer List

		Jeff: I don't have the list - I gave it to you.  How is
the list not responsive ?  Thanks.
		David R. Brake
		Knaggs, Harter, Brake and Schneider, P. C.
		7521 Westshire Dr. Ste 100
		Lansing, MI 48917
		Tx (517) 622-0590
		Fx (517) 622-8463
		[email-masked]

			----- Original Message ----- 
			From: [email-masked] 
			To: [email-masked] 
			Cc: [email-masked] ; [email-masked] 
			Sent: Tuesday, September 16, 2008 2:56 PM
			Subject: Customer List

			David:  In reviewing the customer list for
production, I am concerned that it is not fully responsive to the AG's
requests, reproduced below.  Please advise.  
			 
			9. Identify each person domiciled, residing, or
otherwise located in the Sate of Colorado who purchased a labor law
poster from You or Your affiliates.

			10. For each person identified in response to
Interrogatory 9 above, describe the details of the purchase including
but not limited to identifying the date of the purchase, the method of
order placement, the number of posters ordered, the total order amount
in U.S. Dollars, the method of order payment, and whether the person was
a first-time customer or a repeat customer.

			11. For each person identified in response to
Interrogatory 9 above, describe any subsequent returns of the posters
purchased or requests for refund of the purchase amount including but
not limited to identifying the date of the return or refund request, the
reason for the return or refund request, whether the return was allowed,
whether the refund request was granted, and the amount of any refund
issued.

			Jeffrey Lippa
			Greenberg Traurig, LLP
			The Tabor Center
			1200 17th Street / Suite 2400 / Denver, CO
80202
			Phone:   303-572-6535
			Email:    [email-masked]
<mailto:[email-masked]> 
			<http://www.gtlaw.com/Home> 
			 
________________________________

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