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

Filing 78

WITHDRAWAL OF MOTION PURSUANT TO #80 . . . . . MOTION for Protective Order by PUBLIC.RESOURCE.ORG, INC. (Attachments: #1 Declaration of Andrew P. Bridges In Support of Public.Resource.Org, Inc.'s Motion for Protective Order, #2 Exhibit A - Plaintiffs' Second Requests for Production of Documents, Things and Electronically Stored Information, #3 Text of Proposed Order Granting Defendant's Motion for Protective Order [Dkt. 78])(Bridges, Andrew) Modified on 3/2/2015 (td, ).

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING AND
MATERIALS d/b/a/ ASTM INTERNATIONAL;

Case No. 1:13-cv-01215-TSC-DAR

NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and

DECLARATION OF ANDREW P.
BRIDGES IN SUPPORT OF
PUBLIC.RESOURCE.ORG, INC.’S
MOTION FOR PROTECTIVE ORDER

AMERICAN SOCIETY OF HEATING,
REFRIGERATING, AND AIR-CONDITIONING
ENGINEERS, INC.
Plaintiffs/Counter-defendants,

Filed:

August 6, 2013

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 a member of the bar of the State of California and am 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 Motion for Protective Order.
2.

On January 26, 2015, Public Resource received a second set of requests for

production of documents from the AERA Plaintiffs in the AERA Case, Case No. 1:14-cv-00857TSC-DAR. These requests for production included requests for “responses to all sets of
Requests for Production of Documents and Things served by the ASTM Plaintiffs in the ASTM
case,” “responses to all sets of Requests for Admissions served by the ASTM Plaintiffs in the
ASTM case,” and “all transcripts and exhibits from any depositions taken in the ASTM Case.” A

copy of the AERA Plaintiffs’ second set of requests for production of documents is Exhibit A to
this declaration.
I declare under penalty of perjury that the foregoing is true and correct. Executed on
February 20, 2015.

/s/Andrew P. Bridges
Andrew P. Bridges

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