Hepting et al v. AT&T Corp. et al

Filing 196

Declaration of Bruce A. Ericson in Support of 195 Memorandum in Opposition of Defendant AT&T Corp. to Motion of Lycos, Inc. and Wired News for Orders Permitting Intervention and Unsealing Documents [DKT. 139] filed byAT&T Corp., AT&T Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I, Part One# 10 Exhibit I, Part Two# 11 Exhibit J# 12 Exhibit K)(Related document(s) 195 ) (Ericson, Bruce) (Filed on 6/12/2006)

Hepting et al v. AT&T Corp. et al

Doc. 196

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PILLSBURY WINTHROP SHAW PITTMAN LLP BRUCE A. ERICSON #76342 DAVID L. ANDERSON #149604 JACOB R. SORENSEN #209134 MARC H. AXELBAUM #209855 BRIAN J. WONG #226940 DANIEL J. RICHERT #232208 50 Fremont Street Post Office Box 7880 San Francisco, CA 94120-7880 Telephone: [phone] Facsimile: [phone] Email: [e-mail] SIDLEY AUSTIN LLP DAVID W. CARPENTER (admitted pro hac vice) BRADFORD A. BERENSON (admitted pro hac vice) DAVID L. LAWSON (admitted pro hac vice) EDWARD R. McNICHOLAS (admitted pro hac vice) 1501 K Street, N.W. Washington, D.C. 20005 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants AT&T CORP. and AT&T INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

TASH HEPTING, GREGORY HICKS, CAROLYN JEWEL and ERIK KNUTZEN on Behalf of Themselves and All Others Similarly Situated, Plaintiffs, vs. AT&T CORP., AT&T INC. and DOES 1-20, inclusive, Defendants.

No. C-06-0672-VRW DECLARATION OF BRUCE A. ERICSON IN SUPPORT OF OPPOSITION OF DEFENDANT AT&T CORP. TO MOTION OF LYCOS, INC. AND WIRED NEWS FOR ORDERS PERMITTING INTERVENTION AND UNSEALING DOCUMENTS [DKT. 139] Courtroom: Judge: Hearing: Time: 6, 17th Floor Hon. Vaughn R. Walker June 23, 2006 9:30 a.m.

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I, BRUCE A. ERICSON, declare as follows: 1. I am an attorney licensed to practice law in the State of California and

admitted to practice before this Court, and am a partner of the law firm of Pillsbury Winthrop Shaw Pittman LLP, counsel for defendant AT&T CORP. ("AT&T"). Except for those matters stated on information and belief, which I believe to be true, I have personal knowledge of the facts stated herein and, if called as a witness, I could and would competently testify thereto. 2. On January 31, 2006, Wired News ("Wired") published on its website an

article entitled "AT&T Sued Over NSA Eavesdropping." A true and correct copy of the article is attached hereto as Exhibit A. 3. On April 7, 2006, Wired published on its website an article entitled

"Whistle-Blower Outs NSA Spy Room." A true and correct copy of the article is attached hereto as Exhibit B. 4. On April 7, 2006, Wired published on its website an article entitled

"Wiretap Whistle-Blower's Account." A true and correct copy of the article is attached hereto as Exhibit C. 5. On April 12, 2006, Wired published on its website an article entitled

"AT&T Seeks to Hide Spy Docs." A true and correct copy of the article is attached hereto as Exhibit D. 6. On May 2, 2006, Wired published on its website an article entitled "Feds

Go All Out to Kill Spy Suit." A true and correct copy of the article is attached hereto as Exhibit E. 7. On May 17, 2006, Wired published on its website an article entitled

"Stumbling Into a Spy Scandal." A true and correct copy of the article is attached hereto as Exhibit F. 8. On May 17, 2006, Wired published on its website an article entitled "AT&T

Whistle-Blower's Evidence." A true and correct copy of the article is attached hereto as Exhibit G.

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9.

On May 17, 2006, Wired published on its website an article entitled "Court

Deals AT&T a Setback." A true and correct copy of the article is attached hereto as Exhibit H. 10. On May 22, 2006, Wired published on its website an article entitled

"Whistle-Blower's Evidence, Uncut." A true and correct copy of the article (including a hyperlinked .pdf described as "the complete file") is attached hereto as Exhibit I. 11. On May 22, 2006, Wired published on its website an article entitled "Why

We Published the AT&T Docs." A true and correct copy of the article is attached hereto as Exhibit J. 12. On May 25, 2006, Wired published on its website an article entitled "Court

Filing Confirms Spy Docs." A true and correct copy of the article is attached hereto as Exhibit K. I declare under penalty of perjury that the foregoing is true and correct. Executed on June 12, 2006, at San Francisco, California.

/s/ Bruce A. Ericson Bruce A. Ericson

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