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IBM 3/9/04 Letter to SCO Asking for 1,000 Names & SCO's 3/26/04 Reply - PDF & text
Sunday, January 30 2005 @ 06:42 AM EST

Here's IBM's March 9 letter to SCO [PDF], asking them to give them a list of all the potential witness names they wish IBM to provide contact information for. Of course, that was then. Now it is 3,000. Thanks to moonbroth for transcribing it. The letter is followed by SCO's letter of reply [PDF], with their list of names.

These are just two of the exhibits attached to IBM's Declaration of Amy Sorenson, in support of their Memorandum in Opposition to Renewed Motion to Compel Discovery [PDF], and they were filed as paper exhibits. Our thanks to Frank Sorenson for scanning them for us. I hope some of you are in a mood to do some transcribing, because we have more now.

The letters are about the thousand names that Judge Wells had told IBM to hand over contact information for in her order back in March. SCO had asked for all 7,200 names, and Wells ordered 1,000, with a review afterward if she thought more were needed. SCO's list in reply is rather careless, though. If you only get 1,000, why would you ask for contact information on people you must know how to contact already, like Bill Sandve? Very odd. Maybe because you already know you'll just be asking for more anyway? SCO is like the grave. It never gets enough and stops. And indeed, it pressed for more and while they didn't get all 7,200 they asked for (is someone not subtracting 1,000?), the list was increased to 3,000 in the most recent order.

This text is also more evidence of my sincerity in trying to catch up and complete our text collection. If those wacky guys in Lindon would calm down a minute and let us get up-to-date on their prior activities before they come up with more headline-making reasons to sue somebody, I'd really appreciate it. Just a short time out, of course. It couldn't be more fascinating, really.

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

Cravath, Swaine & Moore LLP
[address]

March 9, 2004

SCO v. IBM; IBM v. SCO

Dear Mark:

In accordance with Judge Wells' March 3, 2004 Order, please let me know for which 1,000 persons identified by IBM in response to SCO's Interrogatory Nos. 4 and 5 you wish to obtain contact information. IBM will search its records for contact information for these 1,000 persons, and will provide SCO with any contact information found.

Very truly yours,
[signature]
Peter Ligh

Mark Heise, Esq.
Boies, Schiller & Flexner LLP
[address]

FEDERAL EXPRESS


Boies, Schiller & Flexner letterhead

March 26, 2004

Via Facsimile

Peter Ligh
Cravath Swaine & Moore LLP
[address]

Re: The SCO Group v. IBM

Dear Peter:

In response to your request for the thousand names for which SCO seeks complete contact information as required by the interrogatories, SCO would like such information for people in the following categories:

1. All persons listed on Exhibit E to IBM's Answers to Interrogatories.
2. All persons identified on the attached document.

As further review necessitates, I will provide you with additional names until we reach 1000. Thank you for your attention to this matter.

Very truly yours,

___[signature]____
Mark J. Heise

MJH/vb

1. Amundson, David
2. Barrett, Pat
3. Bennett, Kathy
4. Bissell, John
5. Bowen, Nick
6. Brooks, Bruce
7. Bulko, William
8. Bullis, David
9. Butler, Robert
10. Casey, Bill
11. Costa, Marcus
12. Dare, Lisa
13. Day, Michael
14. Dobbs, Sharon
15. Easterly, Kent
16. Eastley, Kent
17. Ellis, Sam
18. Felts, Paul
19. Freitas, Kaena
20. Frye, Dan
21. Gevertz, Phil
22. Griffin, Cathy
23. Guarino, Trink
24. Gugleta, Jim
25. Hall, C. David
26. Handy, Scott
27. Harsford, Marshall
28. Hartnett, Sheila
29. Hintze, Herbert
30. Hirsch, Linda
31. Hitchcock, Michael
32. Hobbs, Jeff
33. Hobbs, Sharon
34. Hocraffer, Henry
35. Hunt, Teri
36. Johnson, Prentice
37. Jones, Bruce
38. Kalmeta, Randy
39. Keeler, Pam
40. Keen, R.G.
41. Kennedy, Ted
42. LeBlanc, Robert
43. Lee, Wilson
44. Limvere, FJ
45. Mach, Roger
46. Madden, Walt
47. Maldonado, Norma
48. Malone, Pam
49. Malone, Tom
50. McAbel, John
51. McKenna, Terry
52. McNamee, Haig
53. Mehaffy, David
54. Nelson, Scott
55. Nielson, Peter
56. Norwood, Lillian
57. Novak, Frank
58. Payne, Marilyn
59. Ragan, Janice
60. Rhoden, Joseph
61. Richardson, David
62. Royse, Patty
63. Sandve, Bill
64. Scales, John
65. Schneider, Craig
66. Smallwood, Kevin
67. Smith, Karen
68. Smith, Ron
69. Smith-Kerker, Penny
70. Solazzo, Steve
71. St. Pierre, Ron
72. Stewart, Brad
73. Timms, George
74. Tyson, Thomas
75. Wallin, David
76. Williams, John
77. Wilson, Lawrence
78. Worthington, Greg
79. Wright, Drew
80. Wright, Sara
81. Young, Ray


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