Free Affidavit - District Court of Delaware - Delaware

Case 1:05-cv—OO86®F Document 71-6 Filed 12/$005 Page1 of 3
Byrnes, Andrew C.
From; Plimack, Michael K. ‘ l
Sent; Tuesday, August 09, 2005 9:27 AM
TO; 'Wyss, John'
cc; Nadler, Carl S.; Stephen E. Noona (E-mail)
subjgct; RE: Inline v Verizon Protective Order (Delaware Format)
.
Inline - Redllned
protective 0... . . .
John - attached are our comments to the protective order. We will provide the names
of counsel for the Highly Confidential category shortly.
W e understand that the Court does not typically enter two-tiered protective orders. However, we will
not object to Verizon's proposing such an order to the Court, and therefore have followed the form
you have provided.
I look forward to hearing from you. Thanks.
----- Original Message ---—-
From: Wyss, John [mailto:[email protected]]
Sent: Friday, August 05, 2005 12:23 PM
To: Plirnack, Michael K.
Cc: Inline WRF
Subject: FW: Inline v Verizon Protective Order (Delaware Format)
Mike —- per your request, attached is the Word version of the draft Protective Order we sent to Carl
Nadler on July 15, 2005.
<$WRFMAlN-12355597-v3-InIine_v_Verizon_Protective_Order_(DeIaware_Format).DOC>>
NOTICE: This message (including any attachments) from Wiley Rein & Fielding LLP may constitute
an attorney-client communication and may contain information that is PRIVILEGED and
CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. if you are not an intended recipient, you are
hereby notified that any dissemination of this message is strictly prohibited. If you have received this
message in error, please do not read, copy or forward this message. Please permanently delete all
copies and any attachments and notify the sender immediately by reply email or by calling our
Administrative Office at 202.719.7201. Thank You.
1

Case 1:05-cv—00866;JJF Document 71-6 Filed 12/14/2005 Page 2 of 3
i
Byrnes, Andrew C.
From: Plimack, Michael K.
Sent: Wednesday, August 10, 2005 3:04 PM
To: 'Wyss, John' -
Cc: Nadler, Cari S.; Stephen E. Noona (E-mail)
Subject: RE: Inline v Verizon Protective Order (Delaware Format)
Inline - Clean ‘
prmcuve Om" John - here is a nonredlined version.
-—-—— Original Message —-—-- l · l
From: Wyss, John [mai|to:[email protected]] . ‘
Sent: Wednesday, August 10, 2005 2:01 PM
To: Plimack, Michael K.
Cc: Nadler, Carl S.; Stephen E. Noona (E-mail)
Subject: RE: Inline v Verizon Protective Order (Delaware Format)
Mike -— I am having a little difficulty following the numbering on the redlined version. Could you
please send a clean versions as well.
Thanks. · `
John B. Wyss I
Wiley, Rein & Fielding LLP .
1776 K Street, NW
Washington, DC 20006
Phone: 202.719.7038 '
Fax: 202.719.7049
Email: [email protected]
----- Original Message ----- I
From: Plimack, Michael K. [maiIto:[email protected]]
Sent: Tuesday, August O9, 2005 12:27 PM
To: Wyss, John
Cc: Nadler, Carl S.; Stephen E. Noona (E-mail)
Subject: RE: Inline v Verizon Protective Order (Delaware Format)
John - attached are our comments to the protective order. We will provide the names of counsel for
the Highly Confidential category shortly.
We understand that the Court does not typically enter two-tiered protective orders. However, we will
not object to Verizon‘s proposing such an order to the Court, and therefore have followed the form
you have provided.
l look fonlvard to hearing from you. Thanks.
1

Case 1:05-cv—0O866§F Document 71-6 Filed 12/1 $005 Page 3 of 3
----- Original Message --—--
From: Wyss, John [maiIto:[email protected]] _ I
Sent: Friday, August 05, 2005 12:23 PM
To: Pllmack, Michael K;
Cc: Inline WRF
Subject: FW: Inline v Verizon Protective Order (Delaware Format)
Mike -- per your request, attached is the Word version of the draft Protective Order we sent to Carl
Nadler on July 15, 2005.
<>
NOTICE: This message (including any attachments) from Wiley Rein 8. Fielding LLP may constitute
an attorney-client communication and may contain information t·hat is PRIVILEGED and '
CONFIDENTIAL and/or ATTORNEY WORK PRODUCT. If you are not an intended recipient, you are
hereby notified that any dissemination of this message is strictly prohibited. lf you have received this
message in error, please do not read, copy or forward this message. Please permanently delete all
copies and any attachments and notify the sender immediately by reply email or by calling our
Administrative Office at 202.719.7201. Thank You.
The information contained in this email message may be privileged, confidential and protected from
disclosure. lf you are not the intended recipient, any dissemination, distribution or copying is strictly
prohibited. lf you think that you have received this email message in error, please notify the sender
by reply email and delete the message and any attachments.
2