Miller v. Facebook, Inc. et al

Filing 93

RESPONSE to re 86 Letter by Facebook, 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)(Avalos, Julio) (Filed on 11/29/2010)

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Miller v. Facebook, Inc. et al Doc. 93 Att. 1 EXHIBIT A Case3:10-cv-00264-WHA Document90-2 Dalton, Amy From: Sent: T o: Cc: Subject: Filed11/23/10 Page2 of 9 Brian Hancock [] W ednesday, October 13, 2010 3:11 PM Avalos, Julio Gray, Thomas; Dalton, Amy RE: Miller v. Facebook, Inc. & Yeo/Past Due Discovery Responses Julio, Thank you for this information. As described in your e-mail below, I have no problem with the confidentiality distinctions. I look forward to receiving the approved mark-ups from your client. Thanks, Brian D. Hancock, Esq. Heninger Garrison Davis, LLC 2224 1st Avenue North Birmingham, AL 35203 (205) 327-9112 (direct) (205) 326-3336 (office) (205) 326-3332 (fax) The contents of this e-mail message and any attachments are confidential and are intended solely for addressee. The information may also be legally privileged. This transmission is sent in trust, for the sole purpose of delivery to the intended recipient. If you have received this transmission in error, any use, reproduction or dissemination of this transmission is strictly prohibited. If you are not the intended recipient, please immediately notify the sender by reply e-mail or phone and delete this message and its attachments, if any. From: Avalos, Julio [] Sent: Wednesday, October 13, 2010 1:32 PM To: Brian Hancock Cc: Gray, Thomas; Dalton, Amy Subject: RE: Miller v. Facebook, Inc. & Yeo/Past Due Discovery Responses Brian, My Outlook says that I replied to you yesterday at 3:10 p.m. PST, but I don't see the e-mail in m y sent mail. I apologize if you're receiving a duplicate e-mail. W e have sent our proposed markup of the protective order to the client and are awaiting their sign-off. The major edit that we have made to the order relates to creating different categories of protected documents. So for instance we're proposing that rather than having one catch-all category, we would have a base level of protection for documents marked CONFIDENTIAL and then a higher-level of protection for documents marked HIGHLY CONFIDENTIAL. Highly confidential documents would be, with limited exceptions, attorneys' eyes only. In addition to attorneys, such documents might be disclosed to experts to whom disclosure is reasonably necessary for this litigation and who have signed an acknowledgment to be bound by the PO, the court and its personnel, court reporters, and the author of the document or the original source of the information. W hile we await our client's feedback on the PO, perhaps we could get started discussing any issues that you anticipate with respect to this new category of protection. 1

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