Subject: Re: Customer List
From: "David R. Brake" <[email-masked]>
To: <[email-masked]>
Cc: "Kriss Gillengerten" <[email-masked]>, "Mike Bishop" <[email-masked]>
Date: Wed, 17 Sep 2008 10:00:36 -0400

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]

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  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?

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    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]

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