August 24, 1999

 

Mr. Robert Lane VIA E-MAIL AND FEDERAL EXPRESS

Warner Publications

Dearborn, Michigan 48121

 

Re: Ford Motor Company

 

Dear Mr. Lane:

 

Our firm has been retained on behalf of Ford Motor Company.

 

Ford Motor Company has directed us to file a complaint against you asserting, inter alia, (1) conversion of Ford property, (2) infringement of Ford's trademarks and copyrights, and (3) interference with Ford contractual relations with its employees.

 

We will file the complaint tomorrow, Wednesday, August 25, 1999, in the United States District Court for the Eastern District of Michigan, in Detroit, Michigan. We will also seek a Temporary Restraining Order from the judge assigned to the case at 10:00 a.m. E.S.T. At this point, we do not know which judge will be assigned the case, but if you telephone our office after 9:30 a.m. E.S.T., we will have the information for you. Alternatively, if you or a representative on your behalf will attend the hearing with the judge, we will meet them at 9:30 a.m. E.S.T. in the Clerk's Office of the United States District Court in Detroit.

 

We will also seek an immediate injunction against you from: (1) copying Ford internal, confidential documents, (2) soliciting Ford employees to obtain confidential documents and trade secrets for you, and (3) using Ford trademarks, including the "FORD OVAL" on and in connection with your website.

 

If you will not be able to attend the hearing tomorrow, or have a representative attend on your behalf, but would like to participate by telephone, please call our offices to provide us a telephone number where you can be reached during the morning and afternoon, so that we can provide that to the Court. In this manner, if acceptable to the Court, we can offer your availability by telephone -- though not in person.