Bryan Pringle v. William Adams Jr et al

Filing 206

DECLARATION of Tal E. Dickstein in response to MOTION to Withdraw Transcripts and Re-File Portions of Previously Filed Transcripts Under Seal 202 filed by Defendants David Guetta, Frederick Riesterer, Shapiro Bernstein and Co. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Miller, Donald)

Tal Dickstein
From:
Sent:
To:
Subject:

Dunn, Katharine N. <[e-mail]>
Thursday, July 07, 2011 10:28 AM
'Cenar, Kara'; Linda M. Burrow; Tal Dickstein; Barry Slotnick; Pink, Jonathan Stuart; Seale,
Merili; Righettini, Justin; 'Ryan Greely'; Ira Gould; Dickie, Dean A.
RE: Pringle matter EMI Supplemental Production

Kara,
In reading this email again, your position makes no sense. Regardless of whether or not we will
agree to a stipulation to be entered with the Court, you are required to provide us with a copy of the
EMI documents immediately. The parties are bound by a stipulated protective order that requires
that we abide by the designations unless we move to challenge those designations with the
Court. Accordingly, you are improperly withholding documents that should have been turned over
weeks ago. We expect to have those documents hand-delivered to our office this morning. We will
then review the documents and determine whether we will agree with your designations for
purposes of a stipulation to be entered with the Court.
Katharine
Katharine Dunn

Attorney at Law
312-460-4226 (direct)
312-460-4288 (fax)
[e-mail]
www.millercanfield.com

From: Cenar, Kara [mailto:[e-mail]]
Sent: Wednesday, July 06, 2011 4:12 PM
To: Dunn, Katharine N.; Linda M. Burrow; 'Tal Dickstein'; 'Barry Slotnick'; Pink, Jonathan Stuart; Seale, Merili; Righettini,
Justin; 'Ryan Greely'; Ira Gould; Dickie, Dean A.
Subject: Pringle matter EMI Supplemental Production
Katharine,
Defendant EMI in the Pringle matter has a supplemental production of Bate No. EMI.PR 00001-0000180 ready for your
inspection. There are financial documents and things in the EMI production that are designated as Highly Confidential
and for which we will need to seek entry of a protective order governing confidentiality. We are asking you to stipulate to
the request for entry of the protective order governing confidentiality for these specific documents. We are asking you to
please come to view the documents (they will be available for your review in our Chicago Office or we can make them
available in our Irvine office) for the purposes of informing us whether you will stipulate to our request for protective order
or whether you will oppose our request. If you stipulate, we will file the stipulation with the Court, with the specific
identity of the documents as requested by the Court. Once entered the documents will be released to Plaintiffs'
counsel. However they remain available in the interim period for your inspection and review at our office.
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If you are willing to stipulate to entry of a protective order specific to the above referenced EMI documents, without review
of the documents in advance, please send us any proposed revisions you may have to the draft stipulated protective order
previously provided to you.
If you would like to review the documents before indicating whether you will stipulate or not to the requested protective
order, kindly let me know of time tomorrow afternoon you would like to stop by for your review.
Please call with any questions you may have.
Kara
Kara E. F. Cenar | BRYAN CAVE LLP

Partner - Chicago
161 North Clark Street, Suite 4300 | Chicago, IL 60601-3315
312.602.5019 direct | 312.698.7419 direct fax
773.818.5272 cell

[e-mail]
www.bryancave.com

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