Free Declaration - District Court of California - California

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 1 of 6

Exhibit A

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 2 of 6

Mark Cramer/Los

To "Patrick N. Keegan, Esq." c:pkeegan(gkmb-Iaw.com::
cc Linda BassettLos Angeles/Kirkland-Ellis(gK&E

Angeles/Kirkland-Ells
02/07/2008 11 :03 PM

bcc
Subject RE: Stanford v. Home Depot Rule 26 Report - Final Draft~

Patrick, .

Why did you delete the reference we included that you agreed to produce a copy of Plaintiffs invoice and proof of what he actually paid? When we talked earlier this evening, you agreed to provide that to us. I don't understand why you're deleting it now. Also, the assertion you added to the report that the exchange
of information on this issue is somehow one-sided is not accurate. You already have a copy

of Mr.

Stanford's invoice from Home Depots files because we attched it to our motion. On the other hand, you didn't attach a copy of Mr. Stanford's invoice to your complaint and we haven't seen a copy of the document that he has in his possession. Thats what we discussed earlier and you agreed to send me a copy of the invoice and proof of the amount Mr. Stanford actually paid in order to show whether he was overcharged. Are you changing your position?
Please get båck to me as soon as possible. We have less than an hour to finalize this and file it. I'm in
my

offce.

Mark

Mark T. Cramer I Kirkland & Ells LLP
777 South Figueroa Street. 39th Floor I Los Angeles, CA 90017

213.680.8412 direct 1213.680.8500 fax i mcramer~kirkland.com email http://ww.kirkland.com/mcramer
"Patrick N. Keegan, Esq." c:pkeegan~kmb-Iaw.com;:

.. .
"

.Patrick N. Keegan, Esq." c:pkeegan(gkmb-Iaw.com;:
02107/200810:46 PM

To "'Linda Bassett'" c:lbassetttQkirkland.com::
cc "'Mark Cramet" c:mcramef('¡:kirkland.com::, "'Stacy
Johnson'. c:sjohnson(gkmb-Iaw.com:: Subject RE: Stanford v. Home Depot Rule 26 Report - Final Draft

..'~'~

Linda: Attched hereto is my revised draft (makg changes which I believe is consistent with . my conversation with Mark) which I am willng to sign. Shall I fax my signatue to you or Mark?
Patrick N. Keegan, Esq. KEEGAN & BAKR, LLP 4370 La Jolla Vilage Drive, Suite 640 San Diego, California 92122 858-552-6752 - Direct line
858-552-6750 - Main lie

. .
Exhibit A
Page 8

858-552-6749 - Facsimile

PRILEGED AND CONFIDENTI: This communication contains confdential inormation which is intended

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 3 of 6

the addressee. It may also c.ontain information that is protected by the Attorney-Client Privilege this communcation by persons other than the addressee is prohibited. If you have received this communication in error, please delete the message from your system and contact the sender by reply e-mail or telephone at (858) 552-6750 as soon as possible. Than you.
only for the use of and/or the Work Product Doctrine. Copyig or distribution of

From: Unda Bassett (mailto:lbassettCWkirkland.com) Sent: Thursday, February 07, 2008 9:42 PM

To: Patrick N. Keean, Esq.
Cc: 'Mark Cramer'; 'Stacy Johnson' Subjec: Stanford v. Home Depot Rule 26 Report - Final Draft

Hi Patrick,

Attached, please find the final draft of the Rule 26 Report, with changes incorporated from our discussion

earlier this evening. If you have any edits, please give me a call so that we can discuss and expedite the
filng. If you have no changes, please sign and fax the signature page.

Thank you,

Linda Bassett I Kirkland & Ellis LLP
777 S, Figueroa St., Suite 3700 I Los Angeles, CA 90017
(213) 680-8152 DIRECT I (213) 808-8160 DIRECT FAX
Ibassettkirkiand.com EMAIL

.Patrick N. Keegan, Esq."
o(pkeeganCWkmb-law.com~

To "'Mark Cramer' o(mcramerCWkirkland.com~
cc "'Linda Bassett'" o(lbassetlCWkirkland.com~, '.Stacy Johnson'"

02107/200805:24 PM

o(sjohnsonCWkmb-iaw.com~

Subje RE: Stanford v. Home Depot Rule 26 Report - DRAFT

ct

Sure. I have a prior commtment that I am rung late for, but how about 6:50 p.m.? Call my cell 619-867-2159.

Patrick N. Keegan, Esq. KEEGAN & BAKR, LLP 4370 La Jolla Vilage Drive, Suite 640 San Diego, Californa 92122 858-552-6752 - Direct line 858-552-6750 - Main line

Exhibit A
Page 9

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 4 of 6

858-552-6749 - Facsimle

PRIVILEGED AND CONFIDENTIA: This communication contains confidential information which is intended
only for the use of

the addressee. It may also contain informaton that is protected by the Attorney-Client Privilege

this communcation by persons other than the you have received this communication in error, please delete the message from your system and contact the sender by reply e-mail or telephone at (858) 552-6750 as soon as possible. Than you.
and/or the Work Product Doctrine. Copying or distnbution of addressee is prohibited. If

From: Mark Cramer (mailto:mcramerCWkirkland.com)
Sent: Thursday, February 07, 2008 5:04 PM

To: Patrick N. Keean, Esq.
Cc: 'Linda Bassett' Subject: RE: Stanford v. Home Depot Rule 26 Report - DRAFT

Patrick,
I've reviewed your changes and.

there are some issues we should discuss before finalizing this. Are you

available to talk this evening?
-- Mark

Mark T. Cramer I Kirkland & Ells LLP
777 South Figueroa Street. 39th Floor I Los Angèles, CA 90017

213.680.8412 direct 1213.680.8500 fax I mcramer~kirkland.com email http://ww.kirkland.com/mcramer
.Patñck N. Keegan, Esq.. oCpkeegan~kmb-law.com:.
To "'Linda Bassett'. oClbassett~kirkland.com;'

(!2107/2008 04:06 PM

cc "'Mark Cramer'" oCmcramer~kirkland.com;.
Subject RE: Stanford v. Home Depot Rule 26 Report - DRAFT

Linda: Attched hereto is my revised draf of the joint Rule 26f report. Once you have made your final edits, please send it to me for my signatue. .

Patrck N. Keegan, Esq.

KEEGAN & BAKR, LLP 4370 La Jolla Vilage Drive, Suite 640 San Diego, California 92122

Exhbit A .
Page 10

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 5 of 6

858-552-6752 - Direct line 858-552-6750 - Main line 858-552-6749 - Facsimile

PRIVIEGED AN CONFIDENTIA: Ths communication contains confdential information which is intended
only for the use of

the addressee. It may also contain information that is protected by the Attorney-Client Privilege

and/or the Work Product Doctrine. Copying or distrbution of addressee is prohibited. If

this communication by persons other than the you have received this communication in error, please delete the message from your

system and contact the sender by reply e-mail or telephone at (858) 552-6750 as soon as possible. Than you.

From: Linda Bassett (mailto:lbassettCWkirkland.com) Sent: Thursday, February 07,20082:15 PM

To: pkeeganCWkmb-law.com .
Cc: Mark Cramer Subject: Stanford v. Home Depot Rule 26 Report - DRAFT

Patrick,
Attached please find our draft of the Rule 26 Report to be jointly fied this afternoon. In light of our short time frame for filing, your prompt attention to the Report is much appreciated. Please insert your edits, e-mail the document back to me for final formatting and review, and fax a signed copy of the signature

page.
Sincerely,

Linda Bassett I Kirkland & Ells LLP
777 S. Figueroa St., Suite 3700 I Los Angeles, CA 90017
(213) 680-8152 DIRECT I (213) 808-8160 DIRECT FAX
Ibassettkirkland.com EMAIL

* * * * * * * * * * * * * * * * * * * * * * * *~ * ~ * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

The information contained in this communication is confidential, may be attorney-client privileged, may

consti tute inside information, and is intended only for
the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by

return e-mail orbye-mailtopostmaster!kirkland.com. and
destroy this communication and all copies thereof, including all attachments.

** ** * ******* *** ** * * ****************** ************ **** *** ***
* * *** ** * * ** * * * * * * * * * ** ** * ** * * ** * * * * * * * *** * * * ** * * * ** ** ** * * * *

The information contained in this communication is confidential, may be attorney-client privileged, may

constitute .inside information, and is intended only for
the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP.

Exhibit A
Page 11

Case 3:07-cv-02193-LAB-WMC

Document 21-2

Filed 03/12/2008

Page 6 of 6

return e-mail orbye-mailtopostmaster&kirkland.com. and
destroy this communication and all copi~s thereof, including all attachments.
* * * ** * * * * * * * * * ** ** * * * * * * * ** * * ** * * ** * * ** * * *** * * * * ** * * * * * * * * *
* * ** * * * * * * * * * * * * * ** ** * ** * * * * * ** * * ** * * * * * * * * * * * * * * * * * * * * * * **

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. I f you have received this communication in error, please notify us immediately by

The information contained in this communication is confidential,. may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Ki~kland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by

return e-mail orbye-mailtopostmaster&kirkland.com. and
destroy this communication and all copies thereof, including all attachments.

*~ * ** * * * ** * * * * * * * * * * * * * * * * * * * * * * * * * * *** ** * * * * * * * * * * * * * * * * * *

20082 7 Rule 26 Reporl FINAU12434299_1 J REVISED BY KEEGAN 020708 2239.DOC

~

Exhibit A
Page 12