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“Four Independence Square I have just returned from a Board of Directors Meeting for the company and wanted to report how pleased the Board is over the outcome in our most recent litigation handled by you and your firm. As you may know, several of the companies who failed to settle the case were hit pretty hard by the jury in that case and the work of you and your team, together with your wise counsel saved us a great deal of money. Please pass on my thanks to your litigation team. In particular, I should tell you that I was most impressed with the performance, as I observed it, of your associate, Maggie Polisi. She did a fine job in arguing for our trade secret protective order, the positive result of which positioned us well for settlement of the case. I do not know her status at the firm, put NCW would be pleased to have her work on other matters for us in the future. Specifically, we have been sued in a matter that is being handled by Cliff Fuller in which a similar issue of trade secrets is involved, and T hope that she can be assigned to that case. I trust that you and your team enjoyed your recent trip. I’/11 get a full report when we meet next week. Warm regards, Mien filjo- Howard Meltzer Vice President General Counsel cc: Ms. Margaret Polisi Parker & Gould C47 POLISI DEPOSITION MATERIALS P&G handled a large, multi-defendant antitrust case brought against several com manufacturers, including NCW. The Suit sought $26,000,000.00 in damages. NCW followed Simon Clark’s superb advice to settle with plaintiff Sears Digital Products for $2.5 million dollar. Sears had sought damages for alleged price-fixing by NCW and others. To make its case, Sears had to prove an unlawful conspiracy. Sears sought certain privileged documents from NCW. The protective order was drafted and argued by Margaret Polisi. The client said that Polisi’s work was exceptional. We won a protective order barring disclosure of NCW’s trade secret documents. This made it difficult for Sears to prove its case. Thus, it jumped at the chance to settle with us. ' sent a thank you letter to Simon Clark and Margaret Polisi on July 8, YR-3

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