Free Letter - District Court of Delaware - Delaware

Case 1:04-cv-01258-SLR Document 46 Filed O4/27/2005 Page 1 of 2
Monnis, Nrcrtors, Ansar & TUNNELL
120I Noitra Manner Srnnntr
P.O. Box IB47
Wtrmtnoron, DELAWARE l9399~l347
302 658 9200
Jam; B. BLUMHNFELD FAX
302 575 7291 .
anm2F... APH} 21 2005
jl:>lumenfcid@mnat. com
BY ELECTRONIC FILING
The Honorable Sue L. Robinson
United States District Court
844 King Street
Wilmington, DE 19801
Re: McKesson Information Systems v. The "l`riZetto Group;
CA. No. 04-1258 (SLR;
Dear Chief Judge Robinson:
I am writing in connection with the telephone conference scheduled for 2:30
tomorrow. Attached as Exhibit A is a sample of the original l\¤IcKesson subpoena served on
about 40 of TriZetto‘s customers and attached as Exhibit B is a sample of a revised subpoena
served on a few additional customers this week. The revised subpoena is consistent with the
letter Mcliesson apparently sent to the earlier recipients, (We did not know about the letter
when we raised this issue, and still do not know who it was sent to, because McKesson did not
send us copies.) In any event, it is readily apparent that Mcliesson has not taken "a sharp knife"
to the subpoena. Indeed, original categories I-3, 8 and ll are identical and the rest have hardly
been changed.
At least one customer (Healthblow) has moved to quash (in the Western District
of New York) because compliance would require "hundreds if not thousands of n1an~hours" and
"several weeks, if not several months." Another customer (Great Lakes Health Plan) has advised
us that it has expressed concerns to Mcliesson with respect to the scope and timing of the
subpoena, as well as to l\/IcKesson's suggestion that it not discuss the matter with TriZetto’s
counsel. In order to avoid inconsistent rulings and undue burdens on the customers (who have
no stake in this litigation), we hope that the scope of the subpoenas can be resolved by this Court
without the need for multiple proceedings in various jurisdictions.
Respectfully,
/s/ Jack B. Blumenfeld
Jack B. Blumenfeld

Case 1:04-cv-01258-SLR Document 46 Filed O4/27/2005 Page 2 of 2
The Honorable Sue L. Robinson
April 27, 2005
Page 2
SBB/bls
ce: Peter T. Dalleo, Clerk (By Hand)
Michael A. Barlow, Esquire (By Hand)
David W. Hansen, Esquire (By Fax)
Jeffrey T. Thomas, Esquire (By Fax)