Sony Computer Entertainment America LLC v. Hotz et al

Filing 94

Letter from [Joint] Plaintiff SCEA and Defendant George Hotz re Proposed Order for March 10, 2011 Hearing. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit A)(Smith, Mehrnaz) (Filed on 3/14/2011)

Sony Computer Entertainment America LLC v. Hotz et al

Doc. 94 Att. 7

EXHIBIT 7

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Gaudreau, Holly
From: Gaudreau, Holly
Sent: Monday, March 14,20111:58 PM

To: 'Stewart Kellar'; 'Jack C. Praetzellis'
Cc: Boroumand Smith, Mehrnaz

Subject: RE: Scheduling a time to M&C re: Proposed Order

Dear Stewart and Jack,
Vi/c;'e reviewed your letter. We do not believe there is a need to seek a two day extension from the Court in submitting a proposed order as it is clear from the parties' multiple exchanges of correspondence that we are at
an impasse.

SCEA's proposed order accurately reflects the Court's orders during the March 10, 2011 hearing. It also allows for the additional meet and confer -- on the impoundment protocol for the search for information related to the circumvention and the protocol for the search for jurisdictional discovery -- as ordered by the Court. Involving TIG in such a meet and confer is necessary to ensure that these tasks will be properly implemented. It is clear that you disagree. Consequently, we plan on submittng our proposed order to the Court with a joint letter explaining that the parties could not agree on the substance or the form of the order. Please provide us your inserts to the letter and your proposed order by 4:00 p.m. today. This will provide the Court with an understanding of our disagreement. Judge Spero can then issue his order based on his rulings at the hearing.

Thanks.
Holly

Holly Gaudreau Kilpatrick Townsend & Stockton LLP Eighth Floor I Two Embarcadero Center! San Francisco, CA 94111
office 415 273 4324 I fax [phone] hgaudreaurgkilpatricktownsend.com I My Profile I VCard

From: Stewart Kellar (mailto:stewart(getrny.com)
Sent: Monday, March 14, 2011 12:48 PM

To: Boroumand Smith, Mehrnaz ,
Cc: Gaudreau, Holly; Jack C. Praetzellis
Subject: Re: Scheduling a time to M&C re: Proposed Order

Hello Holly and Mehmaz,
Please find the attached letter re: the proposed order, thank you.
Stewart Kellar
E-ttomey at LawTM 148 Townsend S1. Ste. 2

San Francisco, CA 94107 [phone]
steWí3rt($etrny.(;Qil
V1,ettQileY_í3llg:l___(;Qm

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The information contained in this email message may be privileged, confidential and protected from disclosure. If you are not the intended recipient, any dissemination, distribution or copying is strictly you think that you have received this email message in error, prohibited. If please notify the sender by reply email and delete the message and any attachments.

On Fri, Mar 11,2011 at 12:45 PM, Boroumand Smith, Mehmaz
-cilbQJ:Qllinal1clrfkilpí3tric;ktowl1SeI1cl.com? wrote: Stewart -- Attached is a draft of the proposed order. I did not include the language about the third party subpoenas issued pursuant to Judge Spero's March 3. 2011 order because he issued his own order about that yesterday. Also, you will see that there is one section that is highlighted and in brackets regarding how we address the "information related to the circumvention of the TPMs in the PS3 System." That language was not ordered by the Court yesterday, although the court did indicate that TIG would be best suited for determining how to address this issue. To that end, we would propose that the parties work with TIG to come up with a protocol to be submitted by the middle of next week. The draft reflects that proposal.
Please provide your edits/comments in red

line format.

Thanks,
Mehrnaz
Mehrnaz Boroumand Smith Kilpatrick Townsend & Stockton LLP
Eighth Floor i Two Embarcadero Center I San Francisco, CA 94111

office 415 2737559 I fax [phone] mboroumand(gkilpatricktownsend.com ! My Profile I VCard

From: Boroumand Smith, Mehrnaz
sent: Thursday, March 10, 2011 7:01 PM

To: Stewart Kellar Cc: Boroumand Smith, Mehrnaz; Gaudreau, Holly; Jack C. Praetzellis
Subject: Re: Scheduling a time to M&C re: Proposed Order

Hi Stewart,

I made some progress on the draft after our call this afternoon and should be able to get the it to you by noon tomorrow or so thereafter.

Mehmaz
Sent from my iPhone
On Mar 10,2011, at 6:18 PM, "Stewart Kellar" -csleWftrt($elIIy.c;Qil? wrote:

Hello Mehrnaz and Holly,

Further to our conversation this afternoon. We would like to have a draft of Judge

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Spero's Order to review by noon tomorrow, Friday March 11,2011. We will then have our edits in to you tomorrow as well. Then we can do further relays of proposed changes over the weekend and have a final version ready well before close of business on Monday. Thank you.
Stewart Kellar
E-ttorney at LawTM

148 Townsend S1. Ste. 2 San Francisco, CA 94107 [phone]
stewa_rt~_etrr1Y&Qm

ww.ettQJJ1~yatlflW&Qil

The information contained in this email message may be privileged, you are not the intended confidential and protected from disclosure. If recipient, any dissemination, distribution or copying is strictly you think that you have received this email message in error, prohibited. If please notify the sender by reply email and delete the message and any attachments.

On Thu, Mar 10,2011 at 3:10 PM, Stewart Kellar -cstewart($etrny.com? wrote: Hello Jim, Mehmaz, and Holly,
I am writing to follow up on a message I left for each of you seeking to schedule a time to meet and confer regarding Judge Spero's Order. We want to meet tomorrow to that Order. We have scheduled a conference room at MBV Law discuss the terms of for 1 lam tomorrow, March 11,2011. Please confirm you can make that time. We look forward to discussing the Order at that time.
Sincerely,
Stewart Kellar

E-ttorney at LawTM 148 Townsend S1. Ste. 2

San Francisco, CA 94107 [phone] stewaIi($.etmy,ÇQil
wWW,eltQrneY.al1aW&Qil

The information contained in this email message may be privileged, confidential and protected from disclosure. If you are not the intended recipient, any dissemination, distribution or copying is strictly prohibited. If you think that you have received this email message in error, please notify the sender by reply email and delete the message and any attachments.

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