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)

Miller v. Facebook, Inc. et al

Doc. 93 Att. 6

EXHIBIT F

Dockets.Justia.com

Case3:10-cv-00264-WHA Document90-7 Dalton, Amy
From: Sent: T o: Cc: Subject:

Filed11/23/10 Page2 of 5

Brian Hancock [[e-mail]] Thursday, November 11, 2010 3:08 PM Avalos, Julio Chatterjee, I. Neel; Gray, Thomas RE: Stipulated Protective Order (Redlined Draft)

Julio, I have no problem with that. As requested in my email dated November 9th, and in light of the Plaintiff's pledge to abide by the terms of the agreedupon protective order prior to formal entry by the Court, please confirm whether or not Facebook is willing to respond to Plaintiff's discovery requests now that the parties are in agreement.
Brian D. Hancock, Esq. Heninger Garrison Davis, LLC 2224 1st Avenue North Birmingham, AL 35203 [phone] (direct) [phone] (office) [phone] (fax) [e-mail]

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 [mailto:[e-mail]] Sent: Thursday, November 11, 2010 12:38 PM To: Brian Hancock Cc: Chatterjee, I. Neel; Gray, Thomas Subject: RE: Stipulated Protective Order (Redlined Draft) Brian, I think we're just about there on the protective order. However, I wanted to get your thoughts on Section 8(e) regarding source code inspection logs. As currently drafted, the provision reads:

(e)

The Receiving Party shall maintain a record of any individual who has inspected any portion of

the source code in electronic or paper form. The Receiving Party shall maintain all paper copies of any printed portions of the source code in a secured, locked area. The Receiving Party shall not create any electronic or other images of the paper copies and shall not convert any of the information contained in the paper copies into any electronic format. The Receiving Party shall only make additional paper copies if such additional copies
1