Specht et al v. Google Inc et al

Filing 337

MOTION by Defendant Google Inc for protective order (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Finn, Herbert)

EXHIBIT C

Page 1 of 3

Fassl, Sheri (Secy-Chi-IP-Tech)
From:

John B. Haarlow [[e-mail]]

Sent:

Wednesday, September 29, 2010 4:24 PM

To:

Finn, Herbert (Shld-Chi-IP-Tech); John Shonkwiler; P. Andrew Fleming;
[e-mail]

Cc:

Nelson, Cameron (Shld-Chi-IP-Tech); Dunning, Jeffrey (Assoc-Chi-IP-Tech)

Subject: RE: Specht/Google

Herb - This message confirms that all copies of the unredacted invoice in our possession have been deleted
and/or destroyed.
John

From: [e-mail] [mailto:[e-mail]]
Sent: Tuesday, September 28, 2010 4:20 PM
To: John Shonkwiler; John B. Haarlow; P. Andrew Fleming; [e-mail]
Cc: [e-mail]; [e-mail]
Subject: Specht/Google
Counsel,
We have yet to receive your respective confirmations that all copies of the unredacted invoice have been deleted
and/or destroyed. Your confirmation is appreciated.
Herb Finn
Herbert H. Finn
Shareholder
Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
Tel [phone] | Fax [phone]
[e-mail] | www.gtlaw.com

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5/9/2011

Page 2 of 3

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From: Dunning, Jeffrey (Assoc-Chi-IP-Tech)
Sent: Friday, September 24, 2010 2:39 PM
To: 'John Shonkwiler'; 'John B. Haarlow'; 'P. Andrew Fleming'; '[e-mail]'
Cc: Nelson, Cameron (Assoc-Chi-IP-Tech); Finn, Herbert (Shld-Chi-IP-Tech)
Subject: RE: Specht/Google
Counsel, further to my last e-mail attached please find a redacted copy of the August 18, 2010 invoice.
Sincerely,
Jeff Dunning
Jeffrey P. Dunning
Associate
Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
Tel [phone] | Fax [phone]
[e-mail] | www.gtlaw.com

From: Dunning, Jeffrey (Assoc-Chi-IP-Tech)
Sent: Friday, September 24, 2010 1:38 PM
To: 'John Shonkwiler'; 'John B. Haarlow'; 'P. Andrew Fleming'; '[e-mail]'
Cc: Nelson, Cameron (Assoc-Chi-IP-Tech); Finn, Herbert (Shld-Chi-IP-Tech)
Subject: RE: Specht/Google
Importance: High
Counsel:
It has come to our attention that the e-mail sent to you this morning inadvertently included as an attachment an
unredacted copy of Greenberg Traurig's August 18, 2010 invoice to Google, rather than the redacted
version that we understood was sent. Please be advised that that invoice comprises
the confidential litigation work product of Greenberg Traurig and Google, and its transmittal was
entirely inadvertent and unintentional.
Accordingly, we request that you immediately delete all electronic copies of that invoice that may currently reside
in your computer system(s), and we will provide a replacement redacted copy shortly. Please respond at your
earliest convenience with your acknowledgement that you have deleted all electronic copies of that invoice.

5/9/2011

Page 3 of 3

Sincerely,
Jeff Dunning
Jeffrey P. Dunning
Associate
Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
Tel [phone] | Fax [phone]
[e-mail] | www.gtlaw.com

From: Finn, Herbert (Shld-Chi-IP-Tech)
Sent: Friday, September 24, 2010 9:37 AM
To: John Shonkwiler; 'John B. Haarlow'; P. Andrew Fleming; [e-mail]
Cc: Dunning, Jeffrey (Assoc-Chi-IP-Tech); Nelson, Cameron (Assoc-Chi-IP-Tech)
Subject: Specht/Google
Counsel,
In furtherance of the Court's June 25, 2010 Order, attached are copies of invoices for the court reporter and
videographer for Mr. Murphy's July 31st deposition. Also attached is a copy of Greenberg Traurig's August 18,
2010 invoice to Google, which has been redacted except for those entries related to Mr. Murphy's deposition. For
convenience, payment under the June 25th Order may be made to our firm, which will in turn reimburse Google.
Your early attention to this matter is appreciated.
In addition, we would appreciate your confirmation that the Court fine required under the June 25th Order has
similarly been paid.
Herb Finn
Herbert H. Finn
Shareholder
Greenberg Traurig, LLP | 77 West Wacker Drive | Suite 3100 | Chicago, IL 60601
Tel [phone] | Fax [phone]
[e-mail] | www.gtlaw.com

ALBANY · AMSTERDAM · ATLANTA · AUSTIN · BOSTON · CHICAGO · DALLAS · DELAWARE · DENVER · FORT LAUDERDALE · HOUSTON · LAS
VEGAS · LONDON* · LOS ANGELES · MIAMI · NEW JERSEY · NEW YORK · ORANGE COUNTY · ORLANDO · PALM BEACH COUNTY ·
PHILADELPHIA · PHOENIX · SACRAMENTO · SAN FRANCISCO · SHANGHAI · SILICON VALLEY · TALLAHASSEE · TAMPA · TYSONS CORNER ·
WASHINGTON, D.C. · WHITE PLAINS
*OPERATES AS GREENBERG TRAURIG MAHER LLP

5/9/2011