Free Motion to Compel - District Court of Delaware - Delaware

Case 1:06-cv-00077-JJF

Document 75

Filed 12/19/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE BALDWIN GRAPHIC SYSTEMS, INC., Plaintiff, v. FIBERWEB SIMPSONVILLE INC. and FIBERWEB, INC. Defendants. ) ) ) ) ) ) ) ) ) )

C.A. No. 06-77 (JJF)

PLAINTIFFS' MOTION FOR IN CAMERA REVIEW AND TO COMPEL PRODUCTION OF DOCUMENTS Pursuant to paragraph 9 of the Stipulated Protective Order (D.I. 42) plaintiff Baldwin Graphic Systems, Inc. moves for in camera review of documents produced by defendants and later asserted to be privileged, and to compel production of all documents found not to be privileged as a result of in camera review. The grounds for the motion are set forth in plaintiff's opening brief, submitted herewith. MORRIS, NICHOLS, ARSHT & TUNNELL LLP

/s/ Julia Heaney (#3052)
Jack B. Blumenfeld (#1014) Julia Heaney (#3052) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 (302) 658-9200 [email protected] Attorneys for Plaintiff, Baldwin Graphic Systems, Inc.

OF COUNSEL: James W. Gould Keith J . McWha MORGAN & FINNEGAN, LLP 3 World Financial Center New York, NY 10281-2101 (212) 415-8700 December 19, 2007
1343057

Case 1:06-cv-00077-JJF

Document 75

Filed 12/19/2007

Page 2 of 3

RULE 7.1.1 CERTIFICATE I hereby certify that the subject of the foregoing motion has been discussed with counsel for the defendants, and that no agreement was reached.

/s/ Julia Heaney (#3052)
Julia Heaney (#3052)

Case 1:06-cv-00077-JJF

Document 75

Filed 12/19/2007

Page 3 of 3

CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on December 19, 2007 I electronically filed the foregoing with the Clerk of the Court using CM/ECF, which will send notification of such filing(s) to the following: Francis DiGiovanni CONNOLLY BOVE LODGE & HUTZ, LLP I also certify that copies were caused to be served on December 19, 2007 upon the following in the manner indicated: BY E-MAIL Francis DiGiovanni CONNOLLY BOVE LODGE & HUTZ, LLP The Nemours Building 1007 North Orange Street Wilmington, DE 19899-2207 Michael E. Zeliger Christopher Centurelli KIRKPATRICK & LOCKHART NICHOLSON GRAHAM LLP State Street Financial Center One Lincoln Street Boston, MA 02111-2950

/s/ Julia Heaney (#3052)
Julia Heaney (#3052) [email protected]