Free Letter - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 312-2 Filed O4/07/2006 Page 1 of 2
Louis C. Bechtle
A I .
O’BRlEN Direct Dial: £1°§Y'§ZZ'8€'QY>’
\-—* [email protected]
é? ROHN, PC
O O
Exh1b1t A
January 6, 2006
q Jack B. Blumenfeld, Esquire Michael A. Barlow, Esquire
Morris, Nichols, Arsht & Tunnell Skadden Arps, Slate, Meagher & Flom
1201 North Market Street One Rodney Square
P.0. Box 1347 " PQO. Box 636
Wilmington, DE 19899-1347 Wilmington, DE 19899
RE: McKesson Infomation Solutions LLC v.
_ The TriZetto Group, Inc.
`No. 04-1258 {SLR) {Q Del.)
Dear Counsel:
The purpose of this letter is to express my appreciation for being provided
with the material by McKesson Information Solutions, LLC (McKesson) attorneys in
order to complete the questions raised resulting in the recent exchange.
I By this letter, I am requesting that TriZetto’s counsel review the material
on its privilege logs in keeping with the standards and orders set forth by the Special
Discovery Master (SDM) in regard to the submissions made by the parties since July
2005.
I am looking forward following review by both sides of receiving from
counsel a final position paper Hom each side as to what remains for the SDM to decide.
Both sides must realize that it is not either contemplated, economically
feasible or reasonable to expect the court, through the SDM or otherwise to review,
document by document, everything on a privilege log. The court must depend on counsel
and cotmsel is entitled to guidance from the court. I think that has been provided through
the SDM rulings made to date. 'I`his letter then is what I would hope would be a tina]
requestfor a fmal review by the parties of documents being withheld to see if further
production can be made by both sides.
1515 Market Street · 16r.h Floor · Philadelpltiu, PA 19102-1916 · T: 215.864.96Ul) - F: 215.864.96%) · www.cogr.com

Case 1 :04-cv—O1258-SLR Document 312-2 Filed O4/07/2006 Page 2 of 2
CONRAD o·BRmN GELLMAN & norm, PC
January 6, 2006 ‘
Page 2 .
I will be out of the country imtil January 17*]* and I would ask both parties
to use that time to bring us up to date so we can conclude- this discovery feature of this
litigation.
Sincerely,
LCB/jrw