Disney Enterprises, Inc. et al v. Hotfile Corp. et al

Filing 92

NOTICE by Columbia Pictures Industries, Inc., Disney Enterprises, Inc., Twentieth Century Fox Film Corporation, Universal City Studios Productions LLLP, Warner Bros. Entertainment Inc. re 91 Redacted Document,, Plaintiffs' Notice of Filing Declaration of Luke C. Platzer in Support of Plaintiffs' and the MPAA's Motion to Authorize Use of Categorical Privilege Logs (Attachments: # 1 Affidavit Declaration of Luke C. Platzer in Support of Plaintiffs' and the MPAA's Motion to Authorize Use of Categorical Privilege Logs (Public Redacted Version), # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(Stetson, Karen)

EXHIBIT B

From:
Sent:
To:
Cc:
Subject:

Platzer, Luke C
Thursday, June 02, 2011 7:46 PM
[e-mail]; [e-mail]
Pozza, Duane; [e-mail]; Fabrizio, Steven B; [e-mail]
RE: Disney v. Hotfile - Privilege Log Categories

Tony and Deepak –
As per our call today, the parties will agree to continue the initially-proposed (albeit not-yet-entered) June 15 date for
the exchange of privilege logs (with the new date to be determined), and you will consider our proposal for both parties
to use categorical privilege logs. In order to better understand the categorical privilege logging approach we proposed,
you had asked us to provide a few examples of cases in which courts had agreed endorsed this approach. Here are a
few cases where this approach has been utilized, although we are aware of several others:
Orbit One Communications, Inc. v. Numerex Corp., 255 F.R.D. 98 (S.D.N.Y. 2008)
Republic Service Inc. v. American Intern. Specialty Lines Ins. Co., No. 07-21991-CIV, 2008 WL 4691836 (S.D. Fla. Oct. 21,
2008)
In re Imperial Corp. of America, 174 F.R.D. 475 (S.D. Cal. 1997)
In re Motor Fuel Temperature Sales Practices Litig., No. 07-md-1840, 2009 WL 959491 (D. Kan. April 3, 2009)
Once you have had a chance to think about this issue further (as well as do any research of your own), let’s discuss
again, perhaps on Monday or Tuesday?
Regards,
Luke

From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, June 01, 2011 4:50 PM
To: Platzer, Luke C; [e-mail]; [e-mail]
Cc: Pozza, Duane; [e-mail]
Subject: RE: Disney v. Hotfile - Privilege Log Categories
Luke -- We are amenable to extending the June 15 deadline. Let us know what you have in mind for a new deadline. As
for the other issue, Deepak and I are available to discuss that with you tomorrow morning at 10 a.m. PST if that works for
you.
-----Original Message----From: Platzer, Luke C [mailto:[e-mail]]
Sent: Tuesday, May 31, 2011 8:55 AM
To: Gupta, Deepak (22) x4419; Thompson, Rod (27) x4445
Cc: Pozza, Duane; Leibnitz, Andrew (21) x4932; Schoenberg, Tony (28) x4963
Subject: Disney v. Hotfile - Privilege Log Categories

Deepak and Rod –
As I mentioned on our call last week, we would like to have a call soon to discuss the upcoming privilege log
deadline. In particular, we would like to discuss (1) our proposal to reduce the mutual burdens by utilizing
categorical privilege logs for this litigation, and (2) to mutually extend the currently-proposed June 15 deadline.
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Please let us know when a good time to discuss might be – we believe that this call should involve attorneys
handling both sides of discovery, as it is a global issue involving both parties’ respective productions.
-

Luke

Luke C. Platzer
Jenner & Block LLP
1099 New York Avenue, N.W.
Suite 900
Washington, DC 20001-4412
Tel [phone]
Fax [phone]
[e-mail]
www.jenner.com

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