Dunstan et al v. comScore, Inc.
Filing
269
DECLARATION of Chandler Givens regarding motion for protective order 268 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Thomassen, Benjamin)
EXHIBIT E
Amir Missaghi
Fwd: Dunstan et al. v. comScore, Inc., Case No. 1:11cv5807
Chandler Givens
Fri, Nov 8, 2013 at 4:36 PM
To: Robyn Bowland
Cc: Rafey Balabanian , Jay Edelson , Ben Thomassen
, Andy Schapiro , Stephen Swedlow
, Paul Stack , Amir Missaghi
Robyn:
Here’s a quick followup from our telephone call earlier today. As I explained, we can’t agree to provide comScore with
all of the file listings and web browsing history (“Disputed Data”) from Dunstan’s HD given the data’s highly sensitive
nature and the fact that we don’t believe it’s relevant to this lawsuit. Therefore, we plan on filing a motion to exclude the
Disputed Data on Monday.
During our call you also said that comScore agreed to extracting email headings from Dunstan’s HD limited to the
timeframe that we previously discussed (January 1, 2010 to September 30, 2010). If your expert is able to provide those
emails to us by this evening, then we’ll attempt to review them for potentially contestable data over the weekend and
include them with the other Retrieved Data that we’re giving to comScore on Monday (i.e., the Windows registry, event
logs, and log files). If not, then we may need to inform the Court that a few additional days are necessary to complete
our review. Please let us know either way.
Have a nice weekend.
Thanks,
Chandler
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