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

Filing 51

REPLY to opposition to motion re #41 MOTION to Compel Discovery filed by PUBLIC.RESOURCE.ORG, INC.. (Attachments: #1 Declaration of Andrew P. Bridges in Support of Defendant's Reply re Motion to Compel Discovery, #2 Exhibit 1 to Declaration of Andrew Bridges, #3 Errata 2 to Declaration of Andrew Bridges)(Bridges, Andrew)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING AND
MATERIALS d/b/a ASTM INTERNATIONAL;
NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and
AMERICAN SOCIETY OF HEATING,
REFRIGERATING, AND AIR CONDITIONING
ENGINEERS,

Case No. 1:13-cv-01215-TSC
DECLARATION OF ANDREW P.
BRIDGES IN SUPPORT OF
DEFENDANT
PUBLIC.RESOURCE.ORG, INC.’S
REPLY IN SUPPORT OF MOTION TO
COMPEL DISCOVERY

Plaintiffs-Counterdefendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant-Counterclaimant.
I, Andrew P. Bridges, hereby declare pursuant to 28 U.S.C. § 1746 as follows:
1.

I am an attorney duly licensed to practice law in the State of California and

admitted to practice before this Court. I am a partner in the law firm of Fenwick & West LLP
and counsel of record for Defendant-Counterclaimant Public.Resource.Org, Inc. (“Public
Resource”). I submit this declaration in support of Public Resource’s Reply in Support of its
Motion to Compel Discovery. I make the following statements based on personal knowledge
and, if called as a witness, could competently testify regarding each of these statements.
2.

A copy of the letter dated October 10, 2014 from Plaintiff American Society of

Heating, Refrigerating, and Air Conditioning Engineers’ (“ASHRAE”) counsel Andrew Zee to
Public Resource’s counsel Kathleen Lu is Exhibit 1. In this letter, Mr. Zee responds to Public
Resource’s October 8, 2014 letter and notifies Public Resource of ASHRAE’s intent to produce
documents by October 17, 2014.

3.

A copy of the letter dated October 13, 2014 from the American Society for

Testing and Materials’ (“ASTM”) counsel Kevin Fee to me as Public Resource’s counsel in
response to Public Resource’s September 24, 2014 and October 8, 2014 letters, is Exhibit 2. In
this letter, Mr. Fee raises issues relating to search terms, custodians and the parties’ document
production.
I declare under penalty of perjury that the foregoing is true and correct. Executed this
13th day of October 2014.

/s/ Andrew P. Bridges
Andrew P. Bridges

2