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. 2 EXHIBIT B Dockets.Justia.com Case3:10-cv-00264-WHA Document90-3 Dalton, Amy From: Sent: T o: Cc: Subject: Attachments: Brian, Filed11/23/10 Page2 of 27 Avalos, Julio Tuesday, October 19, 2010 4:15 PM 'Brian Hancock' Gray, Thomas; Metanat, Morvarid; Dalton, Amy; Kim, Elizabeth RE: Miller v. Facebook, Inc. & Yeo/Past Due Discovery Responses Comparison Protective Order.pdf; 261003008(4)_Miller Protective Order DRAFT.DOC Please find attached Facebook's proposed edits to the protective order. W e had an issue with respect to tracking changes in the document. In order to allow you to pinpoint our changes, we went ahead and ran a comparison between our proposal and the original court document. This comparison is also attached hereto. The original document is on the left column, with our proposed draft on the right. Lines highlighted in red have been redacted; material underlined in blue has been added. If you have any proposed edits of your own, please go ahead and make them in the .doc file, with track changes on. Thanks, Julio JULIO AVALOS attorney at law ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 MARSH ROAD MENLO PARK, CA 94025-1015 tel 650.289.7184 javalos@orrick.com www.orrick.com From: Brian Hancock [mailto:bdhancock@hgdlawfirm.com] Sent: Wednesday, October 13, 2010 3:11 PM To: Avalos, Julio Cc: Gray, Thomas; Dalton, Amy Subject: 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. 1

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