• Unsealed Declaration of Irving Wladawsky-Berger, VP, Technical Strategy and Innovation, who says he turned over whatever he had to IBM's attorneys, and they reviewed them and found that he didn't have anything responsive to SCO's documents requests, except for two folders on his computer, which he turned over to the attorneys to give to SCO.
• Unsealed Declaration of Andrew Bonzani, who is the Assistant Secretary and General Counsel, whose testimony is that Board Members at IBM don't keep copies of all the corporate documents, which are collected at the end of Board of Director meetings by his staff. That policy would help to explain why you wouldn't find such documents in the personal files of board members.
• Unsealed Declaration of Alec S. Berman, one of IBM's inhouse attorneys, who says he and Cravath's Peter Ligh went to Sam Palmisano's office on February 18 and 19 to review files and look for documents responsive to SCO's document request, and on both dates, they found documents, which they turned over to Cravath. Later he was informed by Cravath that they had turned over more than 1,000 pages of responsive and non-privileged documents to SCO.
• Unsealed Declaration of Samuel J. Palmisano, CEO and Chairman of the Board of IBM, who declares that he allowed IBM and Cravath attorneys unrestricted access to all his documents, hard copy, soft copy, and email. They searched on February 18 and 19 and took whatever they wanted that they felt would be responsive to SCO's documents requests.

These are all declarations in response to Magistrate Judge Brooke C. Wells' discovery order. As you will recall, she asked IBM's David Marriott at the hearing in October of 2004 if IBM would be willing to provide such, and he said yes, and it was so ordered in her January 18th discovery order.