Veterans for Common Sense et al v. Nicholson et al

Filing 114

Attachment 11
Declaration of William D. Janicki in Support of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation filed byVeterans United for Truth, Inc, Veterans for Common Sense. (Attachments: # 1 Exhibit 1 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 2 Exhibit 1 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 3 Exhibit 3 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 4 Exhibit 4 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 5 Exhibit 5 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 6 Exhibit 6 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 7 Exhibit 7 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 8 Exhibit 8 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 9 Exhibit 9 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 10 Exhibit 10 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 11 Exhibit 11 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 12 Exhibit 12 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation, # 13 Exhibit 13 to Janicki Decl. ISO of Plaintiffs' Reply to Motion for Protective Order Restricting Disclosure of Confidential and Private Information and Prohibiting Retaliation)(Janicki, William) (Filed on 2/6/2008)

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Veterans for Common Sense et al v. Nicholson et al Doc. 114 Att. 11 Dockets.Justia.com RECEIVED U S Department of Justice .. Civil Division Morrison & Foerster JAN 2 5 WOB Washington, D. 20530 C. January 22,2008 Ms. Heather Moser Morrison & Foerster 425 ,Market St. San Francisco, Cal. 94105-2482 RE: Veterans for Common Sense v. Mansfield, (N.D. Cal. No. C-07-3758) By: Regular mail and E-mail [Hmoser@mofo.com] Dear Ms. Moser: This is in response to your letter of January 16,2008 and that of Mr Erspamer of the same date. As to documents requested by plaintiffs, defendants will attempt to prioritize our production of the documents responsive to the requests identified in your letter. However we obviously cannot provide any assurance that we will be able to produce all of the documents responsive to these requests prior to the February 22,2008 preliminary Injunction hearing. Additionally, we anticipate objecting to several of these document requests, as well as of Your letter is incorrect in its assertion that defendmts have waived any such objections. ,while we are sure that plaintiffs would protect the confidentiality of any Ynvacy Act material produced by defendants, that assurance does not provide defendants with the legal authority ta 1 disclose documents that are subject to the Privacy Act; only a court order can provide defenda 1 'th that authority. On the question of depositions, we suggest that plaintiffs identi& a list of proposed deponents and the issues on which you believe that the witnesses would have relevant testimony. Defendants will then be in a position to determine whether they can agree that any depositions in excess of ten are justified. It will likely facilitate prompt discovery production if the parties can agree on the appropriate scope of discovery. To that end, when we discuss plaintiffs' discovery requests, it

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