On October 04, 2013 a
Letter,Correspondence
was filed
involving a dispute between
Albert Perez
Individually And Derivatively On Behalf Of Total Computer Software Llc,
and
John Doe Corporation,
Total Computer Group, Llc,
Total Computers, Ltd.,
Total Computer Software Llc,
Total Computer Systems, Ltd.
D B A Total Computer Group,
Vincent Tedesco,
for Commercial Division
in the District Court of Suffolk County.
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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
Document Filed Date
April 22, 2016
Case Filing Date
October 04, 2013
Category
Commercial Division
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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