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  • Albert Perez INDIVIDUALLY AND DERIVATIVELY ON BEHALF OF TOTAL COMPUTER SOFTWARE LLC v. Vincent Tedesco, Total Computer Systems, Ltd. d/b/a Total Computer Group, Total Computer Group, Llc, Total Computers, Ltd., John Doe Corporation, Total Computer Software LlcCommercial Division document preview
  • Albert Perez INDIVIDUALLY AND DERIVATIVELY ON BEHALF OF TOTAL COMPUTER SOFTWARE LLC v. Vincent Tedesco, Total Computer Systems, Ltd. d/b/a Total Computer Group, Total Computer Group, Llc, Total Computers, Ltd., John Doe Corporation, Total Computer Software LlcCommercial Division document preview
  • Albert Perez INDIVIDUALLY AND DERIVATIVELY ON BEHALF OF TOTAL COMPUTER SOFTWARE LLC v. Vincent Tedesco, Total Computer Systems, Ltd. d/b/a Total Computer Group, Total Computer Group, Llc, Total Computers, Ltd., John Doe Corporation, Total Computer Software LlcCommercial Division document preview
  • Albert Perez INDIVIDUALLY AND DERIVATIVELY ON BEHALF OF TOTAL COMPUTER SOFTWARE LLC v. Vincent Tedesco, Total Computer Systems, Ltd. d/b/a Total Computer Group, Total Computer Group, Llc, Total Computers, Ltd., John Doe Corporation, Total Computer Software LlcCommercial Division document preview
						
                                

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ALSTONSBIRDu» 90 Park Avenue New York, NY 10016 212-210-9400 Fax; 212-922-3884 wwwa.alston.com. Michael E. Johnson Direct Dial: 212-210-9584 Email: michael.johnson@alston.com April 22, 2016 VIA ECF and EMAIL (t.sklar@devittspellmanlaw.com) Theodore D. Sklar, Esq. Devitt Spellman Barrett, LLP 50 Route 111, Suite 314 Smithtown, NY 11787 Re: Perez v. Tedesco Index No. 063193/2013 Dear Mr. Sklar: We represent Defendants/Third Party Plaintiff in the above-captioned matter. In response to your letter of April 13, 2016 concerning our motion for a protective order and Plaintiff/Third Party Defendant’s motion to compel, we provide the following additional information: 1 Great Plains Accounting Softwar Attached hereto as Exhibit 1 is an affidavit from one of Total Computer Group’s (“Group”) Senior Network Engineers, Paul Nevola, concerning the Great Plains accounting software. Attached to Mr. Nevola’s affidavit is a Statement of Work from Micro-Force, a Microsoft partner, detailing the cost and work associated with extraction of Software’s Great Plains accounting data in read-only format. ConnectWise Attached hereto as Exhibit 2 is an affidavit from Chris Repetti, a Senior Network Engineer for Group, concerning the ConnectWise customer data management and work ticketing software. Attached to Mr. Repetti’s affidavit is an email from Connect Wise detailing the cost and work associated with copying a read-only version of the Connect Wise database. We will supplement the information contained in Mr. Repetti’s affidavit early next week with a submission from a consultant with expertise in Criminal Justice Information Services (“CJIS”) compliance requirements, and an affidavit from the individual responsible for Group’s CJIS certification. Allanta + Beijing * Brussels» Charlotte* Dallas* Los Angeles » New York+ Research Triangle Silicon Valley* Washington, D.C. 1 of 2 April 22, 2016 Page 2 We hope that this information proves useful. Should you have any questions or require anything further, please do not hesitate to contact us. Very truly yours, ce: Timothy McEnaney, Esq. (via ECF) 2 of 2