1. ray’s changes
Prepared for:
Alison Wheeler
Bartlit Beck Herman Palenchar & Scott
1899 Wynkoop, Suite 800
Denver, Colorado 80202
August 14, 2000
Dear Alison;
Brian and I enjoyed talking with you after our lab visit on Wednesday. I think we now have a much
better idea of the issues and challenges of your case and consequently, a better idea of where we
might help you demonstrate your client’s story.
We briefly discussed the possibility of meeting with you and your expert to hammer out details he
may want to include. I would like to do that as soon as we can. Our work is meant to demonstrate
expert testimony because in situations where admissibility is a concern, it is important that
demonstratives are developed under the direction of the attorney and/or testifying expert. It is a
practice I like to follow even in alternative resolution situations because it maintains professional
standards.
Theme:
I think that the primary story in this case was most succinctly stated by you as “this is what we
bought…this is what we got.” It was our consensus that we needed three main visuals: (1) an
introduction to the various steps in photo-processing, (2) a visual depicting the equipment systems
and their intended functions within a photo lab and (3) the failure of those pieces of equipment
perform.
Our thoughts on presenting this information are as follows.
Tutorial 1: Introduce the Traditional Photo-processing system
Using a simple animated pictographic flow diagram, we will illustrate the individual steps
that a photo lab would use to process and print film. Each step will be represented by a
small picture-graphic. On-screen labeling will give us any additional information we need
and a photograph or footage of a typical piece of equipment or process step will zoom out to
show us a typical lab scenario.
Tutorial 2: What our client thought it was buying….or…the state of a working system
Building on the above representation of the traditional system, we will open up the diagram
and add the ProLink modules. Flow arrows and onscreen text will show how the ProLink
system was represented to expand the capabilities of an existing traditional system.
Tutorial 3: Demonstrate what our client actually received
Building on the final screen in section 2 we’ll highlight, one at a time, the aspects of the

2. ProLink expanded system that did not function as represented. At any stopping point in the
flow where either the equipment just didn’t work or where there were no detailed design
plans or protocols for testing, we can fly out a screen showing the equipment and include
on-screen text to add specific detail.
Tutorial 4: Contract language screens
For the sake of this estimate, we will create five (5) screens that define certain pertinent
terms such as “technologically feasible”, “Beta testing” and any other language.
Tutorial 5: Timeline ($1,580.00 – 2,898.80)
A 2-panel, hinged, laminated exhibit board showing a visual chronology.
The following quotes are best estimates only, based on the information as we currently
understand it. It is expected that these prices may change as we explore this work together.
You will be fully informed of any changes and adjustments and in full control of approvals
for these changes and adjustments.
Estimated cost: $13,350-20,559
With your approval of this proposal, we will begin immediately to develop a set of storyboards to
discuss with you and your expert(s) at our upcoming meetings.
Thanks so much for your time.
Chris Thomas
Senior Producer
Z-Axis Corporation
HYPERLINK mailto:ct@zaxis.com ct@zaxis.com
Z-Axis Corporation
Production Department
Proposal