Rimkus Consulting Group Inc. v. Cammarata - Ballard Spahr LLP

Case 4:07-cv-00405 Document 450 Filed in TXSD on 02/19/10 Page 51 of 139
(Id. at 35:1–:9). DeHarde testified that the policy remained in effect after the Louisiana state
suit was filed. (Id. at 34:9–:14).
On June 11, 2009, the defendants produced approximately 103 pages of emails sent
in the fall of 2006. The emails include communications among the defendants clearly
responsive to long-standing Rimkus discovery requests. These emails were forwarded from
Gary Bell to defense counsel Larry Demmons on May 15, 2009. These emails were only a
portion of those sent or received by Bell, Cammarata, and DeHarde beginning in the fall of
2006, relating to U.S. Forensic.
Rimkus was able to obtain numerous additional emails via subpoena from the
defendants’ internet service providers and email providers. Most were produced by
Homestead. These emails show that Bell and Cammarata contacted Rimkus clients in
November and December 2006 to solicit business for U.S. Forensic. The following emails
were obtained from Homestead:
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On November 9, 2006, Bell emailed Doug Delaune of Southern Farm Bureau
Casualty Insurance and attached U.S. Forensic’s marketing materials. (Docket
Entry No. 324, Ex. F). Bell asked for Delaune’s help in getting U.S. Forensic
on Farm Bureau’s approved list and invited Delaune to meet. (Id.).
On November 15, 2006, Bell emailed Stephanie Jackson of Louisiana Citizens
Property Insurance and attached “initial company information on U.S.
Forensic.” (Docket Entry No. 321, Ex. L-2). Bell thanked Jackson for
“speaking with [him] last week” and asked for a meeting “some time next
week” to “go over our capabilities, capacities, the company insurance
coverages, and how we plan to improve on services to Citizens.” (Id.). Bell
stated that U.S. Forensic would be “officially open for business tomorrow” and
that he “hope[d] we get a chance to continue working with you.” (Id.).
On November 15, 2006, Bell emailed Don Livengood, a Fidelity National
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