Connectu, Inc. v. Facebook, Inc. et al

Filing 328

DECLARATION re #327 Response to Motion by Facebook, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Cooper, Monte)

Connectu, Inc. v. Facebook, Inc. et al

Doc. 328 Att. 4

EXHIBIT D

Dockets.Justia.com

Page 1 of 2

Dalton, Amy
From: Sent: To: Michael Petrella [[e-mail]] Thursday, January 07, 2010 2:01 PM Cooper, Monte; Sean O'Shea; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; Pashman, Scott; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail] Facebook/Connectu - OHS Litigation Team Only; Joczek; Sbauer; Simpson, Lisa T.; Thompson, Karen; Parris, Mark

Cc:

Subject: RE: Correspondence Dated 1/05/10

Monte: We have complied with and will continue to comply with all applicable orders, agreements, and privileges according to their terms and the law. You have no right to the information you request, and it will not be provided. Regards,
____________________________ Michael E. Petrella O'Shea Partners LLP 521 Fifth Avenue, 25th Floor New York, New York 10175 212.682.4426 T 212.682.4437 F www.osheapartners.com

CONFIDENTIALITY NOTICE: This transmission, and any attached documents and files, may contain information which is protected by the attorneyclient privilege and/or the attorney workproduct doctrine and/or may otherwise be considered privileged and/or confidential. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited and may be contrary to law. If you have received this transmission in error, you are hereby directed to delete this message and to destroy all copies, including all electronic files and printouts, and to notify me by reply e mail at [e-mail] or by telephone at (212) 6824426.

From: Cooper, Monte [mailto:[e-mail]] Sent: Tuesday, January 05, 2010 8:03 PM To: Michael Petrella; Sean O'Shea; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; Pashman, Scott; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail] Cc: Facebook/Connectu - OHS Litigation Team Only; Oczek, Jeremy; Sbauer; Simpson, Lisa T.; Thompson, Karen; Parris, Mark Subject: Correspondence Dated 1/05/10

1/7/2010

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Counsel: Please find attached correspondence dated today. Also, please note that we are copying former Defendant Wayne Chang's new counsel on the attached letter, and on this email. Thank you, Monte Cooper "EMF <orrick.com>" made the following annotations. -----------------------------------------------------------------------------=========================================================== IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication, unless expressly stated otherwise, was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.

=========================================================== NOTICE TO RECIPIENT: THIS E-MAIL IS MEANT FOR ONLY THE INTENDED RECIPIENT OF THE TRANSMISSION, AND MAY BE A COMMUNICATION PRIVILEGED BY LAW. IF YOU RECEIVED THIS EMAIL IN ERROR, ANY REVIEW, USE, DISSEMINATION, DISTRIBUTION, OR COPYING OF THIS E-MAIL IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY OF THE ERROR BY RETURN E-MAIL AND PLEASE DELETE THIS MESSAGE FROM YOUR SYSTEM. THANK YOU IN ADVANCE FOR YOUR COOPERATION. For more information about Orrick, please visit http://www.orrick.com/ =========================================================== ==============================================================================

1/7/2010