Free Declaration - District Court of Delaware - Delaware

Case 1:04-cv—01266—SLR Document 120 Filed 05/24/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
p FOR THE DISTRICT OF DELAWARE
In re: Teieglobe Comm. et al., ) Chapter Il
) lointly Administered
Debtors. )
) Bankr. Case No. 02-11518 (l\/[FW)
Teleglobe USA Inc. et al., g I
Plaintiff, I
v. g Civ. Action No. O4—l266 (SLR)
BCE Inc. et al., g
Defendants. g
DECLARATION OF JOHN W. SHAW
IN SUPPORT OF DEFEN})ANTS’ MEMORANDUM
IN OPPOSITION TO VARTEC’S AMENDED MOTION FOR A PROTECTIVE ORDER
John W. Shaw, pursuant to Rule 9011 of the Federal Rules of Bankruptcy
Procedure and 28 U.S.C. § 1746, declares as follows:
l. I ant a member of the Bar of the State of Delaware and a partner of the
firm of Young Conaway Stargatt 8:. Taylor, LLP, located at 1000 West Street, 17th Floor,
Wilmington, Delaware, attorneys for defendants BCE, Inc. ("BCE”), Michael T. Boychuk, Mare
A. Bouchard, Serge Iiortin, Terence J. Iarmarr, Stewart Verge, Jean C. Monty, Richard J. Currie,
Thomas Kierans, Stephen-}?. Skinner, and H. Arnold Steinberg (the “Defendants"). I submit this
declaration in support of the Defendants’ Memorandum in Opposition to VarTeo’s Amended
_ Motion for Protective Order Regarding Dei`endants’ Second Request for Production of
Documents.

Case 1:04-cv—01266—SLR Document 120 Filed 05/24/2005 Page 2 of 3
2. Attached hereto as Exhibit 1 is a true and correct copy of Defendants’
Second Request for Production of Documents and Directed to the Debtors, dated December 22,
2004.
3. Attached hereto as Exhibit 2 is a true and correct copy of Emergency
Motion of Var't`ec Telecom Inc. and VarTec Telecom Holding Company to Stay Arbitration
Proceedings and Supporting Brief dated January 20, 2004.
4. Attached hereto as Exhibit 3 is a true and correct copy of VarTec’s Motion
to Compel Production of Documents, dated April 8, 2004, and submitted in the arbitration styled
T eleglobe Telecom Corp., etal. v. Vari" ec Telecom, Inc., et al., N0. 50 T 153 00025 04.
5. Attached hereto as Exhibit 4 is a true and correct copy of The Debtors’
Response to Defendants’ Second Request for Production of Documents, dated January 24, 2005.
6. Attached hereto as Exhibit 5 is a true and correct copy of a letter to
Russell C. Silberglied from Daniel Schinnnel, dated April 24, 2005.
7. Attached hereto as Exhibit 6 is a true and correct copy of VarTec Telecom
Incfs Amended Motion for Protective Order Regarding Det`endants’ Second Request for
Production of Documents with Request for Oral Argument Thereon, dated March 10, 2005.
8. Attached hereto as Exhibit 7 is a true and correct copy of the Stipulation
and Protective Order between the Defendants and the Plaintiffs, which was so ordered by the
l Court on April 19, 2005.
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Case 1:04-cv—01266—SLR Document 120 Filed 05/24/2005 Page 3 of 3
I declare under penalty of pexjury under the laws ofthe United States of America
that the foregoing is true and correct.
Executed on May 24, 2005. 0
Q ; John W. Shaw
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