Internet Archive v. Shell

Filing 40

Joint STATUS REPORT by Plaintiff Internet Archive. (Wilson, Kenneth)

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Internet Archive v. Shell Doc. 40 Case 1:06-cv-01726-LTB-CBS Document 40 Filed 01/26/2007 Page 1 of 2 KENNETH B. WILSON, State Bar No. 130009 kwislon@perkinscoie.com STEFANI E. SHANBERG, State Bar No. 206717 sshanberg@perkinscoie.com LILA I. BAILEY, State Bar No. 227094 Lbailey@perkinscoie.com PERKINS COIE LLP Four Embarcadero Center, Suite 2400 San Francisco, CA 94111-4131 Telephone: (415) 344-7000 Facsimile: (415) 344-7050 Attorneys for Plaintiff INTERNET ARCHIVE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO INTERNET ARCHIVE, a California 501(c)(3) non-profit organization, Plaintiff, v. SUZANNE SHELL, a Colorado resident Defendant. CASE NO. 1:06-cv-01726-LTB JOINT STATUS REPORT Pursuant to the Court's request at the January 10, 2007 Scheduling Conference, plaintiff Internet Archive and defendant Suzanne Shell hereby submit the following report on their discussions regarding various discovery-related issues. 1. The parties have agreed that they will not destroy any electronically stored information that is relevant to the subject matter of the lawsuit. 2. The parties have agreed that they will exchange electronic data in a reasonable manner and in a usable format. The parties will revisit and address this issue further once written discovery requests have been served. JOINT STATUS REPORT CASE NO. 1:06-cv-01726-LTB 32222-0007/LEGAL12986700.1 Dockets.Justia.com Case 1:06-cv-01726-LTB-CBS Document 40 Filed 01/26/2007 Page 2 of 2 3. The parties have agreed that they will enter into a Stipulated Protective Order Regarding Confidential or Proprietary Information which will permit both parties to designate materials in a manner such that the materials and the information and content contained therein will not be used or disclosed by the parties or their representatives (including experts and consultants) outside of the context of this lawsuit. Counsel for Internet Archive will prepare the initial draft of the Stipulated Protective Order. 4. The tenor of the parties' conference was positive and cooperative. Dated: January 26, 2007 PERKINS COIE LLP By /s/ Kenneth B. Wilson Kenneth B. Wilson Attorneys for Plaintiff Internet Archive Dated: January 26, 2007 IN PRO SE By: /s/ Suzanne Shell Suzanne Shell In Pro Se -2JOINT STATUS REPORT CASE NO. 1:06-cv-01726-LTB 32222-0007/LEGAL12986700.1

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