SCO Grp v. Novell Inc

Filing 819

Memorandum of Points and Authorities on the Limitations on Novell's Trial Testimony Imposed by Novell's Own Privilege Objections filed by Plaintiff SCO Group. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8)(Hatch, Brent)

SCO Grp v. Novell Inc

Doc. 819 Att. 3

EXHIBIT 3

Dockets.Justia.com

Page 1

IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION C.A. No. 2:04CV00139

THE SCO GROUP, INC., a Delaware corporation Plaintiff and Counterclaim Defendant V. NOVELL, INC., a Delaware corporation Defendant and Counterclaim Plaintiff

-------30(b)(6) Notice to Novell, Inc. Deposition of Joseph A. LaSala, Jr. Wednesday, May 16, 2007 9:41 a.m. Ropes & Gray One International Place Boston, Massachusetts -------Reporter: Deborah Roth, RPR/CSR

Page 8 21:44:30 21:44:35 21:44:39 21:44:42 21:44:47 21:44:49 21:44:52 21:44:55 21:44:55 1 2 3 4 5 6 7 8 9 about external communications about this matter that Novell was engaged in, principally with the press, because his -- one of his responsibilities is press relations. MR. BRAKEBILL: Ted, just so the

record is clear, a few of the people that Mr. LaSala has mentioned are lawyers in the company. It probably is clear, but I just want to make certain on the record that what Mr. LaSala spoke to them about is gathering nonprivileged information that would be responsive to the topics, as opposed to privileged information that would be divulged here. We are not waiving any privilege of conversations he may or may not have had with in-house lawyers with respect to issues in the litigation. BY MR. NORMAND: Q. In your view, did Mr. McBride have

21:44:57 10 21:44:59 11 21:45:00 12 21:45:04 13 21:45:06 14 21:45:06 15 21:45:09 16 21:45:12 17 21:45:15 18 21:45:17 19 21:45:18 20 21:45:18 21 21:45:20 22 21:45:22 23 21:45:26 24

personal or firsthand knowledge of the issues you spoke with him about, or were they more issues of what Novell's interpretation of