Transcribed Message from ISO Counsel re: Document Production

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Colleagues:

Attached hereto is Norma Formanek's transcribed voicemail message confirming
that ISO will not produce documents to plaintiffs until after a protective
order has been entered in whichever court this case winds up. As discussed,
I propose to send the following confirming letter:

"Thank you for your voicemail confirming that ISO is continuing to abide by
our agreement that there will be no production of documents to plaintiffs'
counsel until after plaintiffs' remand motion has been heard and we know
which court will be entering the protective order that will preserve the
confidentiality of documents that are produced. Defense counsel are
reviewing the proposed protective order and will provide comments in the
near future."

Please let me know if you have any suggestions or changes.

Thanks.

Michael J. Kass
Pillsbury Winthrop LLP
50 Fremont Street, Room 1452
San Francisco, CA 94105
TEL: (415) 983-1462
FAX: (415) 983-1200
email: mkass@pillsburywinthrop.com

- 10515337_1.DOC