Perry et al v. Schwarzenegger et al

Filing 187

MOTION for Protective Order filed by Martin F. Gutierrez, Dennis Hollingsworth, Mark A. Jansson, Gail J. Knight, ProtectMarriage.com - Yes on 8, A Project of California Renewal, Hak-Shing William Tam. Motion Hearing set for 9/25/2009 10:00 AM in Courtroom 6, 17th Floor, San Francisco. (Attachments: #1 Exhibit A -- Reply Br. for Aplt., Citizens United v. FEC, #2 Exhibit B -- Prentice Declaration, #3 Exhibit C -- Plaintiffs' First Set of Requests for Production, #4 Exhibit D -- Defendant-Intervenors' Response to Plaintiffs' First Set of Requests for Production, #5 Exhibit E -- Letter of August 27, 2009, #6 Exhibit F -- Letter of August 31, 2009, #7 Exhibit G -- Moss Declaration, #8 Exhibit H -- Doe v. Reec Opinion, #9 Exhibit I -- Schubert Declaration, #10 Exhibit J -- Jannson Declaration, #11 Exhibit K -- Articles Discussing Negative Effects of Public Disclosure, #12 Exhibit L -- Tam Declaration, #13 Exhibit M -- Toupis Declaration, #14 Proposed Order)(Cooper, Charles) (Filed on 9/15/2009)

Perry et al v. Schwarzenegger et al

Doc. 187 Att. 4

Case3:09-cv-02292-VRW Document187-5

Filed09/15/09 Page1 of 2

Exhibit E

Dockets.Justia.com

Case3:09-cv-02292-VRW Document187-5

Filed09/15/09 Page2 of 2

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.