Free Motion in Limine - District Court of Delaware - Delaware

Case 1:04-cv-01266-SLR Document 265-16 Filed 05/23/2006 Page 1 of 2

Case 1 :04-cv-01266-SLR Document 265-16 Filed 05/23/2006 Page 2 of 2
SHEARMAN 8: STERLING LLP
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Maygh 4, 2005 was1—rzr~r0·r01r,D.c.
Via email, facsimile and U.S. mail
Robert J. Malatak
Hahn & Hessen LLP
488 Madison Avenue
New York, New York 10022
Re: Teleglobe Communications Corp., et al., v. BCE Inc., et al.
Dear Mr. Malatak:
We are in receipt of your letter dated March 3, 2005, regarding the discovery you
seek to obtain from Deloitte and Touche and Osler, Hoskin & Harcourt LLP ("Osler"). BCE Inc.
("BCE") has not objected to your efforts to obtain letters of request. BCE will also direct Deloitte
and Touche to provide any documents it received from BCE that are responsive to the subpoena and
were created during the relevant time period, subject to any applicable Canadian privileges. The
remaining documents in Deloitte and 'I`ouche’s files are not within BCE’s possession, custody, or
control. BCE similarly will direct Osler to produce non—privileged documents submitted by BCE to
Osler that are responsive to the subpoena and were created during the relevant time period, subject
to any applicable privileges. We will also ask that Osler provide other responsive non privileged
documents created during the relevant time period, subject to all applicable privileges.
Furthermore, in an effort to assist you in the discovery process in good faith, we will ask BCE for
the address ofthe Canadian repository for Arthur Andersen, if it is known.
Very truly yours,
Daniel Schimmel
cc: C. Malcolm Cochran, IV
Gregory élibayniill-rgbgglerling LLP is a limited liability partnership organized in the United States under
the laws ofthe Slate of Delaware, which laws limit the personal liability afparmers.
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