AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 31

MOTION for Order of Protection by AMERICAN SOCIETY FOR TESTING AND MATERIALS, AMERICAN SOCIETY OF HEATING, REFRIGERATING, AND AIR-CONDITIONING ENGINEERS, INC., NATIONAL FIRE PROTECTION ASSOCIATION, INC. (Attachments: #1 Exhibit A - Proposed Order, #2 Exhibit B - Declaration of Jordana Rubel, #3 Exhibit B - Declaration Exh. 1, #4 Exhibit B - Declaration Exh. 2, #5 Exhibit B - Declaration Exh. 3, #6 Exhibit B - Declaration Exh. 4, #7 Exhibit B - Declaration Exh. 5, #8 Exhibit B - Declaration Exh. 6, #9 Exhibit B - Declaration Exh. 7, #10 Exhibit B - Declaration Exh. 8, #11 Exhibit B - Declaration Exh. 9, #12 Exhibit B - Declaration Exh. 10, #13 Exhibit B - Declaration Exh. 11, #14 Exhibit B - Declaration Exh. 12, #15 Exhibit B - Declaration Exh. 13, #16 Exhibit B - Declaration Exh. 14, #17 Exhibit B - Declaration Exh. 15, #18 Exhibit B - Declaration Exh. 16, #19 Exhibit B - Declaration Exh. 17, #20 Exhibit B - Declaration Exh. 18, #21 Exhibit B - Declaration Exh. 19, #22 Exhibit B - Declaration Exh. 20, #23 Exhibit B - Declaration Exh. 21, #24 Exhibit B - Declaration Exh. 22, #25 Exhibit B - Declaration Exh. 23, #26 Exhibit B - Declaration Exh. 24, #27 Exhibit C)(Fee, J.)

Exhibit 2

Rubel, Jordana S.
Thursday, April 17, 2014 7:10 PM
Mongan, Michael; Corynne McSherry; Andrew Bridges
Kathleen Lu; [e-mail]; [e-mail]; [e-mail];
[e-mail]; Fee, J. Kevin; Clayton, Michael F.; [e-mail];
[e-mail]; [e-mail]; [e-mail]; Klaus, Kelly; Blavin, Jonathan
RE: ASTM et al. v. Public Resource: Meet and Confer
(77932750)_(4)_Protective Order - draft 4-17.DOCX

From:
Sent:
To:
Cc:
Subject:
Attachments:

Counsel,
Attached please find a draft protective order. We can discuss any comments you may have during next Monday’s call.
Best,
Jordana
Jordana S. Rubel
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW | Washington, DC 20004-2541
Direct: +1 202.739.5118 | Main: 202.739.3000 | Fax: [phone]
[e-mail] | www.morganlewis.com
Assistant: Margaret C. Young | +1 202.739.5493 | [e-mail]

From: Mongan, Michael [mailto:[e-mail]]
Sent: Friday, April 11, 2014 8:20 PM
To: Corynne McSherry; Andrew Bridges
Cc: Kathleen Lu; [e-mail]; [e-mail]; [e-mail]; [e-mail]; Fee, J.
Kevin; Clayton, Michael F.; Rubel, Jordana S.; [e-mail]; [e-mail]; [e-mail];
[e-mail]; Klaus, Kelly; Blavin, Jonathan
Subject: RE: ASTM et al. v. Public Resource: Meet and Confer

We can use the following dial-in information for our call on the 21st at 1:30 p.m. pacific
Dial-in:
Code:

888-263-2720
415-512-4051-2

Best,
Mike
From: Corynne McSherry [mailto:[e-mail]]
Sent: Friday, April 11, 2014 10:27 AM
To: Andrew Bridges
Cc: Mongan, Michael; Kathleen Lu; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]; [e-mail]; Klaus, Kelly; Blavin, Jonathan
Subject: Re: ASTM et al. v. Public Resource: Meet and Confer

That works for us.

**********************************************
Corynne McSherry
Intellectual Property Director, EFF
1

https://www.eff.org
415-436-9333 x 122
Join EFF! www.eff.org/join

On Apr 11, 2014, at 10:24 AM, Andrew Bridges wrote:
Hey, my apologies. I’m moving so fast this week that when I read your original message I thought you were talking
about this coming Monday, not Monday April 21. I can do April 21 at the time you suggested, 1:30 pm PT. By copy of
this email let me ask my colleagues to weigh in as to whether it works for them.
Andrew
From: Mongan, Michael [mailto:[e-mail]]
Sent: Friday, April 11, 2014 10:18 AM
To: Andrew Bridges; Kathleen
Lu; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail]; jwetzel@ksl
aw.com; [e-mail]; [e-mail]; Klaus, Kelly; Blavin, Jonathan
Subject: RE: ASTM et al. v. Public Resource: Meet and Confer

Andrew:
For plaintiffs, our window of availability on Wednesday, April 23 is from 10 a.m. to 2 p.m. pacific. Please let
us know what time would work best for your team.
Best,
Mike
From: Andrew Bridges [mailto:[e-mail]]
Sent: Thursday, April 10, 2014 3:23 PM
To: Mongan, Michael; Kathleen
Lu; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail]; jwetzel@ksl
aw.com; [e-mail]; [e-mail]; Klaus, Kelly; Blavin, Jonathan
Subject: RE: ASTM et al. v. Public Resource: Meet and Confer

I am traveling and unfortunately that time would be tough for me. Could you suggest some times possibly on
Wednesday?
Andrew
From: Mongan, Michael [mailto:[e-mail]]
Sent: Thursday, April 10, 2014 3:22 PM
To: Andrew Bridges; Kathleen
Lu; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]
Cc: [e-mail]; [e-mail]; [e-mail]; [e-mail]; jwetzel@ksl
aw.com; [e-mail]; [e-mail]; Klaus, Kelly; Blavin, Jonathan
Subject: ASTM et al. v. Public Resource: Meet and Confer
2

Counsel:
I write on behalf of the plaintiffs to request a meet-and-confer telephone conference regarding discovery.
Among other things, we would like to discuss entering a stipulated protective order (a draft of which we will
circulate shortly), as well as a timeframe for the mutual exchange of search protocols by the parties.
Would you be available for this call at 1:30 p.m. pacific on Monday, April 21? Please let us know if any of that
time works for you, and we can circulate dial-in information.
Best,
Mike
Michael J. Mongan | Munger, Tolles & Olson LLP
560 Mission Street | San Francisco, CA 94105
Tel: [phone] | Fax: [phone] | [e-mail] | www.mto.com
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