Dunstan et al v. comScore, Inc.

Filing 46

DECLARATION of Ray Sardo regarding response in opposition to motion 45 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Somvichian, Whitty)

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EXHIBIT A Sardo, Ray Jay Edelson Uedelson@edelson.com] Friday, October 07, 20111:09 PM Rhodes, Michael Sardo, Ray: cgivens; An Scharg; Somvichian, Whitty; William Gray; Cushing, Thomas Re: Dunstan v. comScore From: Sent: To: Cc: Subject: Nov. 4 is fine. Also, let us know who your e-discovery liason is. On Fri, Oct 7, 2011 at 3:05 PM, Rhodes, Michael <RHODESMGcooley.com> wrote: Tom Cushing (who you met in Chicago aiid cc-ed above) will help set up the access to the data. Ray, will facilitate the time and process too. On response date, given how slammed Whitty and I have been is Nov 4 ok? I will leave to others the logistics of getting you the customer list the court ordered by provided under AIX) protection. Thanks. From: Jay Edelson [mailto:jede1son(edelson.com] Sent: Friday, October 07, 201111:49 AM To: Rhodes, Michael Cc: Sardo, Ray; cgivens; An Scharg; Somvichian, Whitty; William Gray Subject: Re: Dunstan v. comScore Mike, How much time do you want to respond to the complaint? Also, can your team work with Chandler Givens of our firm to get him access to the database, as discussed in court today? Finally, please let us know how we are getting the hard copy list of comScore customers who are receiving notice from comScore? -Jay On Thu, Oct 6, 2011 at 7:05 PM, William Gray <wgray(edelson.com> wrote: Please see the attached \‘:!ri iOfl Vl(iuirc, [.1 (. (.. IL 1.3 12.572.7212 :Jirct 1.3 12.589.6370 wgrayedelson.corn www.edelson.com 1.3 12.589.6378 1 350 North LaSalle Street, Suite 1300 Chicago, Illinois 60654 1.312.589.6375 (direct) 11.312.589.6370 (firm) 11.312.589.6378 (fax) jedelson@edelson.com www.edelson.com Please consider the environment before printing this einail CONFIDENTIALITY AND LIABILITY FOR MISUSE. The information contained in this communication is the property ofEdelsonMcGuire, LLC. It is confidential, may be attorney work product, attomey-client privileged or otherwise exempt from disclosure under applicable law, and is intended only for the use of the addressee(s). Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited. If you have received this communication in error, please notity Edelson McGuire, EEC immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Pursuant to requirements related to practice before the U.S. Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended to be used, and Cannot be used, for purposes of(i) avoiding penalties imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter. c ii “ r w I 33 ec 1’flfl13w auo ‘ft3, fl’. ‘wec U nine d a’, s 1w 0 ‘ I 0 s wart 3I’J ,[Cftiei 3ft’ ft VftOft. 3. I Or ‘ . Or 3 ‘ iflDiii’ riwf 1 1 ii I 0 0 :3 . JtlD3 Oft ii ‘r c ‘-‘ cf Is Or r j Adnentafrotor. 05 Circrutar 200 disotosuro; To ensure rrompl;anco wOO requ;ruments mposeu ny Ore iRS. we nfoim you :1st any U.S 1 tenOr we advice contained in this c’, we rr r c i, 3Xoa len 1cr o is ‘r w “r I en’ c a o n nit r w el I w’c 3 at ch rnrn a cot r U ud a’, Internal Revenue tOnIc or iii) for promoting mt3rletlnft Dr rccornrnefldng to anotts: party cry trarsoc0or :3. netter addressed nondr. :craltes undor . Jay Frd.elsn. i.delson .M.c(uie 1..1.i. 350 North LaSalle Street, Suite 1300 Chicago, Illinois 60654 1.312.589.6375 (direct) 11.312.589.6370 (firm) 11.312.589.6378 (fax) jedelson@edelson.com I www.edelson.com Please consider the environment before printing this e-mail CONFIDENTIALITY AND LIABILITY FOR MISUSE. The information contained in this communication is the property of Edelson McGuire, LLC. It is confidential, may be attorney work product, attomey-cI ient privileged or otherwise exempt from disclosure under applicable law, and is intended only for the use of the addressee(s). Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited If you have received this communication in error, please notify Edelson McGuirc, EEC immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Pursuant to requirements related to practice before the U.S. Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of(i) avoiding penalties imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter. 2

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