Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 209

MOTION TO CLARIFY THE AGREED PROTECTIVE ORDER re #170 Protective Order by Bedrock Computer Technologies, LLC. (Attachments: #1 DECLARATION OF JONATHAN R. YIM, #2 Exhibit A.1, #3 Exhibit A.2, #4 Exhibit A.3, #5 Exhibit A.4, #6 Text of Proposed Order)(Cawley, Douglas)

EXHIBIT A-1

From: To: CC: Subject: Date: Attachments: Todd,

Austin Curry "Todd Briggs"; Diane Hughes; RE: Bedrock Friday, April 23, 2010 1:29:41 PM

Because you have not returned my call or responded to my email, I am instructing Mr. Smith to print three copies of Google's source code. If you or your firm prevent him from doing so, Bedrock will seek reimbursement for costs arising from future, otherwise unnecessary trips to your office by Bedrock's experts. Austin Curry

From: Austin Curry Sent: Friday, April 23, 2010 11:23 AM To: 'Todd Briggs' Cc: Diane Hughes Subject: Bedrock

Todd, I just left you a voicemail. In case you are away from your office, I am repeating it here in email. One of Bedrock's experts, Mr. Smith is currently at your firm's office reviewing source code. He just informed me that someone in your firm is limiting him to print one copy of the source code. This is acceptable only if Google will allow Bedrock to make two copies of the code that we print out. As you know, I proposed on the 20th that the parties agree to modify the Protective Order to allow Bedrock to make two copies, but you have not responded to that proposal.

As such, I need to know whether (i) Bedrock is allowed to make two copies of the code that our experts print or (ii) Mr. Smith can print three copies of the code. Alternatively, let me know if it is your position that each of Bedrock's expert must travel to San Francisco to print copies of code, in which case we will need to call the District's discovery hotline immediately. Because Mr. Smith will only be in San Francisco for today, I will need a response from you as soon as possible. Austin Curry Austin Curry Attorney McKool Smith P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Office: 214.978.4207
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