On November 27, 2007 a
Stipulation,Agreement
was filed
involving a dispute between
Amundin, Andreas,
Blackstone Technology Group, Inc.,
and
Amundin, Andreas,
Does 1-50, Inclusive,
for OTHER NON EXEMPT COMPLAINTS
in the District Court of San Francisco County.
Preview
IT A
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jan-26-2009 4:32 pm
Case Number: CGC-07-469499
Filing Date: Jan-26-2009 2:58
Juke Box: 001 Image: 02382533
ND STIPULATION NOT TO ELICIT TESTIMONY OR ENTER DOCUI
BLACKSTONE TECHNOLOGY GROUP, INC. VS. ANDREAS AMUNDIN et al
001002382533
Instructions:
Please place this sheet on top of the document to be scanned.So 7 NY DH BB WwW wD me
BS RP RP PR RM OR yee Be ee LLL
eoN OA VY RY NEF SO we UF aAR OR SS
~ ~
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP FF t i.
A Limited Liability Partnership San Franciang ©
Including Professional Corporations
JENNIFER G. REDMOND, Cal. Bar No. 144790 JAN 2 6/2005
ADAM J. TULLMAN, Cal. Bar No. 235694 a |
Four Embarcadero Genter, | 7th Floor, ae ORDe alt
San Francisco, California 94111-41 ' i fly
Telephone: 415-434-9100 Benet Cire
Facsimile: 415-434-3947
Attomeys for Third Party Witness
McKESSON CORPORATION
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
BLACKSTONE TECHNOLOGY Case No. CGC-07-469499
GROUP, INC.,
STIPULATION AND [BRSPStED)
Plaintiff, ORDER NOT TO ELICIT
TESTIMONY OR ENTER
v. DOCUMENTARY EVIDENCE
REFERENCING MCKESSON
ANDREAS AMUNDIN, and CONFIDENTIAL INFORMATION
DOES 1 through 50,
Date: January 26, 2009
Defendants. Time: 1:30 p.m.
Dept.: 306
Judge: The Honorable Nancy Davis
Complaint Filed: | November 27, 2007
Trial Date: January 26, 2009
Plaintiff Blackstone Technology Group ("Blackstone") by and through its
attorneys of record, Curiale Dellaverson Hirschfeld and Kraemer, LLP; Defendant
Andreas Amundin ("Amundin"), by and through his attorneys of record, Payne and Fears
LLP; and third party McKesson Corporation ("McKesson") by and through its attorneys of
record Sheppard Mullin Richter and Hampton LLP, agree and stipulate as follows:
-1-
WO02-WEST:SAJT1\401318855.1 NOTICE OF MOTION AND MOTION TO SEAL7 >
1. Third party McKesson conducted an audit into its Generics IT
platform ("Generics Audit") and considers the results of that audit to be highly
confidential.
2. Blackstone and Amundin agree the results of the Generics Audit are
not relevant to the legal and factual issues in dispute between Blackstone and Amundin in
this lawsuit.
3. As a result, Blackstone, Amundin, and McKesson stipulate and agree
that they will not clicit testimony or enter documentary evidence regarding the results of
the Generics Audit. This stipulation and agreement does not preclude the parties from
eliciting testimony or entering documentary evidence regarding the following topics, for
example: 1) that the Generics Audit occurred; 2) that a program was initiated as a result of
the Generics Audit ("Generics Program"); (3) that the Generics Program was a critical
project; (4) that McKesson Business Technology Solutions ("BTS") viewed the Generics
Program as an opportunity to rebuild its working relationship with the Generics business;
and (5) that various software was used in connection with the Generics Program.
4. Blackstone and Amundin further agree to make limited redactions to
the trial exhibits to delete references regarding the results of the Generics Audit. The
parties and McKesson shall meet and confer regarding these redactions.
Dated: January 26, 2009
PAYNE AND FEARS LLP
. .
By Krk lu
CHUCK LOUDERBACK
LEILA NARVID
Attomeys for Defendant ANDREAS AMUNDIN
-2-
W02-WEST:SATTI401318855.1 NOTICE OF MOTION AND MOTION TO SEALco Oo YD mA BRB ww He
BR Pye NN NR NY Be Be ee we ee eR ee LL
San nvn FF NF Soe IA AaAERE BDH OS
“™~
Dated: January 26, 2009
Dated: January 26, 2009
IT IS SO ORDERED
Dated: (+2 é -0f
CURIALE DELAVERSON HIRSCHFELD &
i
By
DENA L. NARBAITZ
GEOFFREY M. HASH
AMY A. DURGAN
Attorneys for Plaintiff
BLACKSTONE TECHNOLOGY GROUP, INC.,
SHEPPARD, MULLIN, RICHTER & HAMPT'
» ke
JENNIFER G. REDMOND
Attorneys for third party MCKESSON
CORPORATION
Judge of the Superior Court
3.
W02-WEST:SAJTIN401318855.1
NOTICE OF MOTION AND MOTION TO SEAL
Document Filed Date
January 26, 2009
Case Filing Date
November 27, 2007
Category
OTHER NON EXEMPT COMPLAINTS
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
IT A SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Jan-26-2009 4:32 pm Case Number: CGC-07-469499 Filing Date: Jan-26-2009 2:58 Juke Box: 001 Image: 02382533 ND STIPULATION NOT TO ELICIT TESTIMONY OR ENTER DOCUI BLACKSTONE TECHNOLOGY GROUP, INC. VS. ANDREAS AMUNDIN et al 001002382533 Instructions: Please place this sheet on top of the document to be scanned.So 7 NY DH BB WwW wD me BS RP RP PR RM OR yee Be ee LLL eoN OA VY RY NEF SO we UF aAR OR SS ~ ~ SHEPPARD, MULLIN, RICHTER & HAMPTON LLP FF t i. A Limited Liability Partnership San Franciang © Including Professional Corporations JENNIFER G. REDMOND, Cal. Bar No. 144790 JAN 2 6/2005 ADAM J. TULLMAN, Cal. Bar No. 235694 a | Four Embarcadero Genter, | 7th Floor, ae ORDe alt San Francisco, California 94111-41 ' i fly Telephone: 415-434-9100 Benet Cire Facsimile: 415-434-3947 Attomeys for Third Party Witness McKESSON CORPORATION SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION BLACKSTONE TECHNOLOGY Case No. CGC-07-469499 GROUP, INC., STIPULATION AND [BRSPStED) Plaintiff, ORDER NOT TO ELICIT TESTIMONY OR ENTER v. DOCUMENTARY EVIDENCE REFERENCING MCKESSON ANDREAS AMUNDIN, and CONFIDENTIAL INFORMATION DOES 1 through 50, Date: January 26, 2009 Defendants. Time: 1:30 p.m. Dept.: 306 Judge: The Honorable Nancy Davis Complaint Filed: | November 27, 2007 Trial Date: January 26, 2009 Plaintiff Blackstone Technology Group ("Blackstone") by and through its attorneys of record, Curiale Dellaverson Hirschfeld and Kraemer, LLP; Defendant Andreas Amundin ("Amundin"), by and through his attorneys of record, Payne and Fears LLP; and third party McKesson Corporation ("McKesson") by and through its attorneys of record Sheppard Mullin Richter and Hampton LLP, agree and stipulate as follows: -1- WO02-WEST:SAJT1\401318855.1 NOTICE OF MOTION AND MOTION TO SEAL7 > 1. Third party McKesson conducted an audit into its Generics IT platform ("Generics Audit") and considers the results of that audit to be highly confidential. 2. Blackstone and Amundin agree the results of the Generics Audit are not relevant to the legal and factual issues in dispute between Blackstone and Amundin in this lawsuit. 3. As a result, Blackstone, Amundin, and McKesson stipulate and agree that they will not clicit testimony or enter documentary evidence regarding the results of the Generics Audit. This stipulation and agreement does not preclude the parties from eliciting testimony or entering documentary evidence regarding the following topics, for example: 1) that the Generics Audit occurred; 2) that a program was initiated as a result of the Generics Audit ("Generics Program"); (3) that the Generics Program was a critical project; (4) that McKesson Business Technology Solutions ("BTS") viewed the Generics Program as an opportunity to rebuild its working relationship with the Generics business; and (5) that various software was used in connection with the Generics Program. 4. Blackstone and Amundin further agree to make limited redactions to the trial exhibits to delete references regarding the results of the Generics Audit. The parties and McKesson shall meet and confer regarding these redactions. Dated: January 26, 2009 PAYNE AND FEARS LLP . . By Krk lu CHUCK LOUDERBACK LEILA NARVID Attomeys for Defendant ANDREAS AMUNDIN -2- W02-WEST:SATTI401318855.1 NOTICE OF MOTION AND MOTION TO SEALco Oo YD mA BRB ww He BR Pye NN NR NY Be Be ee we ee eR ee LL San nvn FF NF Soe IA AaAERE BDH OS “™~ Dated: January 26, 2009 Dated: January 26, 2009 IT IS SO ORDERED Dated: (+2 é -0f CURIALE DELAVERSON HIRSCHFELD & i By DENA L. NARBAITZ GEOFFREY M. HASH AMY A. DURGAN Attorneys for Plaintiff BLACKSTONE TECHNOLOGY GROUP, INC., SHEPPARD, MULLIN, RICHTER & HAMPT' » ke JENNIFER G. REDMOND Attorneys for third party MCKESSON CORPORATION Judge of the Superior Court 3. W02-WEST:SAJTIN401318855.1 NOTICE OF MOTION AND MOTION TO SEAL