`Case 1:17-cv—00868—VAC-SRF Document 9-2 Filed 08/04/17 Page 1 of 3 PagelD #: 166
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`
`
`EXHIBIT B
`EXHIBIT B
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`
`
`Case 1:17-cv-00868-VAC-SRF Document 9-2 Filed 08/04/17 Page 2 of 3 PageID #: 167
`
`Ashraf, Amina
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Justin A. Nelson <jnelson@SusmanGodfrey.com>
`Monday, July 10, 2017 5:25 PM
`Ashraf, Amina; mlowrie@foley.com; Modi, Naveen
`bfarnan@farnanlaw.com; mfarnan@farnanlaw.com; Bill Carmody; Tamar Lusztig;
`mambros@foley.com
`RE: Univ. of Mass. Med. School and Carmel Labs., LLC v. L’Oréal S.A. and L’Oréal USA,
`Inc.
`
`Dear Naveen:
`
`Thank you for your letter of July 7, 2017. It is an inauspicious way to start a dialogue with
`opposing counsel by insinuating a Rule 11 violation. Rest assured, our firms have conducted a
`good faith investigation that more than satisfies Rule 11. Our experience is that further letter-
`writing campaigns on this point make little sense. We strongly disagree that we have somehow
`failed to adequately plead infringement. If, however, you believe in good faith that we have not
`adequately pleaded something, then make your motion. We look forward to interacting with
`you in a cooperative and friendly manner.
`
`On a separate note, can you please let us know whether you will accept service on behalf of
`L’Oreal S.A.? Should you accept, we will of course be amenable to a reasonable extension for
`you to file your responsive pleading on behalf of both defendants. I have included only you and
`Amina Ashraf on this email but please let us know whether we should include others from your
`firm or prior settlement counsel.
`
`Regards,
`
`Justin
`
`
`From: Ashraf, Amina [mailto:aminaashraf@paulhastings.com]
`Sent: Friday, July 07, 2017 2:25 PM
`To: mlowrie@foley.com
`Cc: bfarnan@farnanlaw.com; mfarnan@farnanlaw.com; Bill Carmody; Tamar Lusztig; Justin A. Nelson;
`mambros@foley.com
`Subject: Univ. of Mass. Med. School and Carmel Labs., LLC v. L’Oréal S.A. and L’Oréal USA, Inc.
`
`Counsel,
`
`Please see the attached.
`
`Regards,
`Amina Ashraf
`
`____________________________________________________________________________
`1
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`
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`Case 1:17-cv-00868-VAC-SRF Document 9-2 Filed 08/04/17 Page 3 of 3 PageID #: 168
`
`Amina Ashraf | Client Service Specialist
`Paul Hastings LLP | 875 15th Street, N.W., Washington, DC 20005 | Direct:
`+1.202.551.1230 | Main: +1.202.551.1700 | Fax: +1.202.551.0130 |
`AminaAshraf@PaulHastings.com | www.paulhastings.com
`
`
`
`
`
`
`
`
`******************************************************************************************
`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments.
`
`For additional information, please visit our website at
`
`2
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`
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