Perry et al v. Schwarzenegger et al

Filing 333

Letter from Ethan D. Dettmer re Motion to Compel the Deposition of Doug Swardstrom. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Dettmer, Ethan) (Filed on 12/31/2009)

Perry et al v. Schwarzenegger et al

Doc. 333 Att. 3

Case3:09-cv-02292-VRW Document333-4

Filed12/31/09 Page1 of 2

Exhibit D

Dockets.Justia.com

Case3:09-cv-02292-VRW Document333-4 Monagas, Enrique A.
From: Sent: To: Cc: Subject:

Filed12/31/09 Page2 of 2

Kaylan Phillips [[e-mail]] Tuesday, October 27, 2009 9:11 AM Dettmer, Ethan D.; Monagas, Enrique A. [e-mail] RE: Perry v. Schwarzenegger, N.D. Cal. No. C 09-2292 VRW

Mr. Dettmer, We've reviewed the subpoena. We do need more time to finalize our objections. However, so that we may begin to come to an agreement, we are providing an initial list of requirements below. 1) Jim is unavailable on November 9th as he will be arguing before the Eastern District of Louisiana on that day. We will seek our client's availability and provide alternative dates as soon as possible. 2) Regarding the deposition itself: a. We do not agree to the deposition being videotaped; b. Our client will not disclose his or her identity at any point. 3) Regarding any document production: all identifying information will be redacted prior to production. 4) Further, we will seek a protective order. We must have this order in place prior to the deposition. While we are still finalizing what will be included, at a minimum it will include: a. All protections being afforded to the Proposition 8 committee; b. Specific protections to preserve our client's anonymity; c. An agreement that, if our client's identity is discovered, the parties will agree to keep the client anonymous (absent a court order to the contrary). I look forward to working with you. Kaylan Lytle Phillips Bopp, Coleson & Bostrom 1 South 6th Street Terre Haute, IN 478073510 voice: 8122322434 (ex. 42) fax: [phone] email: [e-mail] NOTICE AND DISCLAIMERS The preceding message may be confidential or protected by the attorneyclient privilege. It is not intended for transmission to, or receipt by, any unauthorized persons. If you believe that this message has been sent to you in error, please (i) do not read it, (ii) reply to the sender that you have received the message in error, and (iii) erase or destroy the message. To the extent this email message contains legal advice it is solely for the benefit of the client(s) of Bopp, Coleson & Bostrom represented by the Firm in the particular matter that is the subject of this message and may not be relied upon by any other party.

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