Case 1:10-mc-00002-LAK Document 194-29 Filed 04/26/11 Page 1 of 3

Exhibit 27
 Case 1:10-mc-00002-LAK Document 194-29 Filed 04/26/11 Page 2 of 3

Berkovits, Yonatan
From: Haggerty, Timothy [thaggerty@fklaw.com]
Sent: Wednesday, March 30, 2011 6:10 PM
To: Neuman, Andrea E.; avinegrad@cov.com; arivero@riveromestre.com; nleino@cov.com;
pdans@riveromestre.com; Mastro, Randy M.; Hendricks, Kristen; bnarwold@motleyrice.com;
mjasinski@motleyrice.com
Cc: Max GITTER; jormand@cgsh.com
Subject: FW: update re: e-mail accounts (3 30 2011)
Attachments: Yahoo subpoena (3 30 2011).pdf

Follow Up Flag: Follow up

Flag Status: Completed

I received a bounce-back when I sent this to the "Group-DonzigerSubpoenas-Counsel-ExternalList@cgsh.com"

address (and, indeed, I did not receive the message and I believe that I am a member of that e-mail
group). Thus, I am resending.

Tim

From: Haggerty, Timothy

Sent: Wednesday, March 30, 2011 6:04 PM
To: Max GITTER
Cc: Group-DonzigerSubpoenas-Counsel-ExternalList@cgsh.com; Kaplan, Bruce S.; 'jormand@cgsh.com'
Subject: update re: e-mail accounts (3 30 2011)

Dear Mr. Gitter:

On behalf of Bruce Kaplan and myself, I write with an update on our efforts to access the contents and
other information related to the accounts: srd.asst@gmail.com, sdonziger2@yahoo.com,
sdonziger@tmo.blackberry.net, and invictusdocs@gmail.com.

 With respect to the gmail accounts, we have submitted the executed Order to Google (via Mr.
Gidari). The written consent required by the Order has been provided to Google.
 Mr. Gidari has advised us that Google is preparing the production for shipment, hopefully for
overnight delivery tonight and by tomorrow in all events.
 With respect to the Yahoo account, we will be sending the attached subpoena by overnight mail to
Yahoo. We have made calls to the General Counsel's office (the office of Michael Callahan) as well
as to Messrs. Jon Berroya and Christian Lee (whom we dealt with in connection with the
documents2010 account). We have not heard back from any of these Yahoo representatives, but
we will impress upon them the urgency of this matter when we speak.
 With respect to the T-Mobile account, our firm has an ongoing attorney-client relationship with T-
Mobile. We have asked T-Mobile for a waiver with respect to this matter, and we have drafted a
subpoena so that we are prepared to effect prompt service when T-Mobile confirms, as we hope it
will, that it waives the conflict.
 We have asked for the best recollections of Mr. Donziger, Mr. Woods and Mr. Low related to the T-
Mobile and Yahoo accounts. Messrs. Low and Woods have advised us that they do not recall either
account. Mr. Donziger has advised us that he does not recall creating, accessing or using the
sdonziger2@yahoo.com account. He advised us that the T-Mobile account may have been his first
Blackberry account, and he may have used it to send a small number of e-mails. He said that he
does not know how to access the account.
 We are working with Mr. Donziger to prepare an appropriate affidavit for submission to Yahoo and
T-Mobile relating to these accounts. We anticipate that we will be in a position to submit the
affidavit to Yahoo and T-Mobile (assuming the conflict is waived) tomorrow.

1
 Case 1:10-mc-00002-LAK Document 194-29 Filed 04/26/11 Page 3 of 3
Respectfully,

Tim Haggerty

Timothy M. Haggerty
Friedman Kaplan Seiler & Adelman LLP
One Gateway Center, 25th Floor
Newark, NJ 07102-5311
Direct tel: 973-877-6451
Direct fax: 973-877-6452

New York Office:

7 Times Square
New York, NY 10036-6516
Direct tel: 212-833-1251
Direct fax: 212-833-1250

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