Perry et al v. Schwarzenegger et al

Filing 175

Letter from Charles J. Cooper to Court re Request for Leave to File Mot. for Protective Order. (Attachments: #1 Enclosure (RFPs), #2 Enclosure (Ltr.), #3 Enclosure (Ltr.))(Cooper, Charles) (Filed on 9/10/2009)

Perry et al v. Schwarzenegger et al

Doc. 175 Att. 1

Case3:09-cv-02292-VRW Document175-2

Filed09/10/09 Page1 of 1

Cooper & Kirk
Lawyers Nicole J. Moss
[e-mail]

1523 New Hampshire Ave., N.W. Washington, D.C. 20036 August 27, 2009

A Professional Limited Liability Company

[phone] Fax [phone]

By Electronic Mail Matthew D. McGill Gibson, Dunn & Crutcher LLP 1050 Connecticut Ave., NW Washington, D.C. 20036-5306 Re: Perry v. Schwarzenegger, et al., U.S.D.C., N.D. Cal., C-09-2292 VRW Dear Matt, We are in receipt of Plaintiffs' First Set of Requests for Production and appreciate the efforts you have made to confine the scope of those Requests to the representations made at the August 19, 2009 hearing. Consistent with those representations, I write to clarify that Defendant-Intervenors understand Plaintiffs' Requests as not calling for the disclosure of Defendant-Intervenors' internal communications and documents, including communications between and among Defendant-Intervenors, as well as communications between DefendantIntervenors and their agents, contractors, attorneys, donors, or others in a similarly private and confidential relationship with Defendant-Intervenors. We also understand your Requests, to the extent they call for communications or documents prepared for public distribution, to call for documents that actually were disclosed to the public. We, in turn, intend to make clear that our discovery requests to individuals and organizations opposed to Proposition 8 will be similarly limited. Sincerely,

Nicole J. Moss Cc: Charles J. Cooper, Esq. David Thompson, Esq.

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