Free Affidavit - District Court of Delaware - Delaware

Case 1 :04-cv-01494-JJF Document 163 Filed O4/25/2007 Page 1 of 2
IN THE UNITED STATES `l)1STR1CT COURT
FOR THE DISTRICT OF DELAWARE

CORPORATION and LAW DEB-`ENTURE
TRUST COM?ANY OF NEW YORK,
Plaintiffs,
v. CA. No. 04~l·494—IJF
NORTHWESTERN CORPORATION,
Defendant.

CORPORATION,
Piaintiffs,
v. C.A. No. 05-—G499—J}F
MIKE J. `HANSON and ERNIE J. KINDT
Defendants.

STATE OF NEW YORK )
COUNTY OF NEW YORK g SSH
JOSEPH D. PIZZURRO, being duly sworn, deposes and says:
l. I have been admitted pro hac vice to the bar of this Court and am a
member of the firm of Curtis, Mallet-Prevost, Colt & Mosie LLP, counsel for defendant
NorthWestein Corporation (“NorthWestern") in the above-referenced action. I submit this
affidavit in further Support of NorthWestern Corporatiorfs Emergency Cross Motion for an
Order that the normal briefing schedule under Local Rule 7).2 be truncated and that an
immediate teiephonic hearing be scheduled end an Order that plaintiffs and their counsel l

Case 1:O4—cv—O1494-JJF Document 163 Filed O4/25/2007 Page 2 of 2
immediately comply with their obligations pursuant io paragraph 8 of the Stipulated Protective
Order of March 21, 2007.
2. Attached hereto as Exhibit l is a true and correct copy ofNorthWesterr1’s
supplemental privilege log which was delivered by email ori April 5, 2007 and by hand on April
6, 2007 to counsel for Plaintiffs, John Brewer.
3. Attached hereto as Exhibit 2 is a true and correct copy of NorthWestern’s
amended supplemental privilege log which was delivered by hand on April 24, 2007 io Mr.
Brewer.
4. On April 24, 2007, eleven replacement discs containing NorthWestem’s
document production, from which all inadvertently produced privileged documents referenced in
the April 3, 5, 12 and 16, 2007 demand letters were removed, were delivered by hand to Mr.
Brewer.
Dated: April 24, 2007 W//7 fp
Ji; X fj i - iz.
ose h Pizzmr ¤_
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Sworn to before me
this Ile"` day of April, 2007
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