Preview
Fredrick A. Hagen, California Bar No. 196220
BERDING & WEIL LLP
F I L EGGUNTY
D
SAN MATEO
2175 N. California Blvd, Suite 500
Walnut Creek, California 94596 AUG 0 2n
Telephone: 925 ~83‘8—2090 2
Facsimile: 925—820—5592
fliagemwzberdingweilcom
Attorneys for Plaintiff
ALI TAGHAVI, an individual
17— GIV— 04570
DIS
Declaration in Support
SUPERIOR COURT OF THE STATE OF CALIFORNIA
1711111111 lllllllllllll!l_ IN AND FOR THE COUNTY OF SAN MATEO
ALI TAGHAVI, an individual, No. 17CIV04570
11
Plaintiff, DECLARATION OF FREDRICK A. .
12 HAGEN IN SUPPORT OF PLAINTIFF’S
vs. MOTION FOR PROTECTIVE ORDER
13 REGARDING DEPOSITIONS OF ALI
THE LELAND STANFORD JUNIOR TAGHAVI
14 UNIVERSITY, a California nonprofit
corporation, doing business as STANFORD Date: September 21, 2018
15 UNIVERSITY; ALTICOR, INC, a Michigan Time: 9:00 a.m.
corporation; and DOES 1-10, inclusive, Dept: L&M 31H
16
'
Defendants.
17 / A3
18 I, Fredrick A. Hagen, hereby declare as follows: xva
19 1. I am an attorney with the law firm of Berding Weil LLP,
|
counsel of record for
20 Plaintiff Ali Taghavi. I have personal knowledge of the facts set forth in this declaration and
21 could competently testify to those facts if called upon to do so.
22 2. This case arises out of Defendant the Leland Stanford Junior University’s (“the
23 University”) termination of lVIr. Taghavi from the University’s School of Medicine. On October
24 4, 2017, Mr. Taghavi filed a complaint against the University for wrongful termination and against
25 Alticor, Inc. (“Amway”) for international interference with prospective economic advantage.
26 3. On July 30, 31, and August 8, 2018, the University and Amway deposed Mr.
27 Taghavi extensively. regarding confidential matters. Given that the parties had agreed to a
28 stipulated protective order, I did not prevent questions regarding this confidential information or
-1-
DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S
BERDING &WEIL, LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI
1175 N Calilomia Blvd sun. son
Walmn Creek. Canton-Ia 94556
suspend the deposition to seek a protective order. On multiple instances during the depositions,
Mr. Taghavi testified to confidential matters regarding his finances, personnel files, work history,
and confidential medical issues and records‘related to his prior employment, all of which are
protected under his right to privacy under the California Constitution. For example, Mr. Taghavi
OLA->035)
discussed his personnel files from his post—termination employers, including compensation records
and employment application documents, which include further confidential information such as
\] third party references. Mr. Taghavi was also asked extensively about similar past employment
history and records, including personnel files subpoenaed from past employers, containing similar
confidential information, including confidential medical information. Mr. Taghavi also testified
10 regarding confidential information related to his employment with the University. A majority of
11 his testimony concerned such confidential matters.
12 4. On July 30, 2018, the'Parties filed a Stipulation and [Proposed] Protective Order
13 Regarding Confidential Information (“the Stipulation”). The Stipulation permits a party to
14 designate any document as confidential that the party “reasonably considers in good—faith to
15 contain information involving trade secrets, or confidential business or financial information,
16 including personal financial information about any party to this lawsuit, putative class members or
17 employee of any party to this lawsuit, information regarding any individual’s banking relationship
18 with any banking institution, including information regarding the individual’s financial
19 transactions or financial accounts, and any informatiOn regarding any party not otherwise available
2o to the public, subject to protection under Rules 2.550, 2.551, 2.580, 2.585, 8.160, and 8.490 of the
21 California Rules of Court or under other provisions of California law.” (Stipulation 1] l.)
22 5. In addition, “A party or non—party may designate information disclosed during a
23 deposition as ‘Confidential’ by so indicating in said responses or on the record at the deposition
24 and requesting the preparation of a separate transcript of such materia .” (Stipulation 1T 2.) “In
25 addition, a party may designate in writing, within thirty (30) days after receipt of said responses
26 or of the deposition transcript for which the designation is proposed, that specific pages of the
27 transcript and/or specific responses be treated as ‘Confidential Information.’ Any other party may
28 object to such proposal, in writing or on the record. Upon such objection, the parties shall
-2-
DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S
BERDING 8. WEIL LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI
1175 N Clfilnmia'Elvd Suits 50!)
Walnul Creek, Callfanila 94536
follow the procedures described in Paragraph 8.” (Stipulation 11 2.)
N 6. According to Paragraph ‘8 of the Stipulation, “[i]f a party contends that any material
is not entitled to confidential treatment, such party may at any time give written notice to the party
or non—party who designated the material. The party or non-party who designated the material
shall have twenty (20) days from the receipt of such written notice to apply to the Court for an
\OooflmUl-hlfl
order designating the material as confidential. The party seeking the order has the burden of
establishing that the document is entitled to protection.” (Stipulation fl 8.)
7. On July 31, 2018, I emailed counsel for Defendants that he designated Mr.
Taghavi’s three depositions, including the transcripts and videos, as confidential (“Designation
10 Notice”). (A true and correct copy of the Designation Notice is attached to this declaration as
11 Exhibit A.)
12 8. I also emailed a “meet and confer” email to counsel for Defendants on August 15,
13 2018. (A true and correct copy of the meet and confer email is attached to this declaration as
14 Exhibit B.)
15 9. Counsel for the University objected to the designation of the July 30-31 deposition
16 in a letter to me dated August 7, 2018 (“University Objection Letter”). Counsel for the University
17 objected to the designation for the August 8 deposition on August 15, 2018 (“University Objection
18 Email”). True and correct copies of the University Objection Letter and University Objection
19 Email is attached to this declaration as Exhibit C and Exhibit D, respectively.)
20 10. Counsel for Amway objected to the designation on August 1 and 17, 2018
21 (“Amway Objection Email”). A true and correct copy of the Amway Objection Email is attached
22 to this declaration as Exhibit E.)
23 11. Because counsel for both Defendants objected when I designated the deposition
24 materials as confidential, I filed this motion under the Stipulation fil 8. Mr. Taghavi seeks a
25 protective order that seals the depositions—including the transcripts and videos—from disclosure
26 to the public.
27 12. Neither the University nor Amway have provided a reason for making MI.
28 Taghavi’s deposition public, including the written deposition transcripts, the Videos taken of the
_3_
DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAINTIFF’S
BERDING & WEIL, LLF MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI
211s "Calilnmia and suits mu
Walnut avuk. Callfomlz Miss
deposition, or the exhibits to the deposition.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed on August 20, 2018 Creek, California.
Yahut
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A IiiEdrick A. Hagen
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X:\Wdocs\8236\91\PLD\0094548 l .DOCX
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DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S
BERDING &WEIL, LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI
1‘ 15 N California Blvd Suite 5013
Walnul Creek, Callfumia 94596
Exhibit A
----- Original Message—----
From: Fredrick A. Hagen [mailtotagen@berdjgweilcom]
Sent: Tuesday, July 31, 2018 10:14 PM
To: Amber Eklof; Kubin, Karen 1.
Subject: [EXT] Taghavi
Amber and Karen,
This will confirm that I am designating Mr. Taghavi’s deposition transcript and video, etc., as confidential under the
stipulated protective order.
Thanks,
Fredrick A. Hagen
Sent from my iPhone
This message may be confidential and privileged. Use or disclosure by anyone other than an intended addressee is
prohibited. If you received this message in error, please delete it and advise the sender by reply email.
Exhibit B
From: Fredrick A. Hagen
Sent: Wednesday, August 15, 2018 1:32 PM
To: Amber Eklof (aeklof@grsm.com)
Cc: kkubin@mofo.com; Emily L. Tetzel; Terri L. Nocco
Subject: RE: Taghavi v. Leland Stanford
Ms. Eklof,
The purpose of this email is to meet and confer regarding your objection to designating the deposition of transcript for
Ali Taghavi’s deposition as confidential, which includes transcripts and videos taken on July 30, July 31, and August 8,
along with the attached exhibits.
You provided no reason for objecting, so l am unable to meet and confer regarding anyjustification you may have. As
you know, Mr. Taghavi was deposed extensively regarding private and confidential personnel and employment related
matters, including Mr. Taghavi's confidential information and the confidential information of third parties. Further, there
is no reason to make the deposition transcripts, videos or exhibits public at this or any time.
Moreover, you and Amway have asserted blanket confidentiality for all documents produced since the parties signed the
stipulated protective order, which includes numerous documents that are not confidential. So the standard you wish to
impose on me you are not following.
Forcing me to identify parts of the deposition that are less confidential and parts that are more confidential is just an
attempt to make me do busy work. There is no reason to make any ofthe deposition public.
Please withdraw your objection to making Mr. Taghavi’s deposition and related video and exhibits confidential so we
can avoid the waste of part and judicial resources.
Thanks,
Fred
Fredrick A. Hagen | Attorney
fhagen@berding—weil.com 1
Profile 1
vCard
BERDINGZWEIL .
ATTORN EYS AT LAW
CELEBRATING
3} YEARS OF EXCELLENCE
WALNUT CREEK COSTA MESA SAN DIEGO
2175 N California Blvd. 575 Anton Blvd. 1660 Hotel Circle North
Suite 500 Suite 1080 Suite 701
Walnut Creek Costa Mesa San Diego
CA 94596 CA 92626 CA 92108
P 925.838.2090 P 714.429.0600 P 858.625.3900
F 925.820.5592 F 714.429.0699 F 858.525.3901
www.berdingwei|.com |
Linkedln I Facebook
This communication is intended to be protected by all applicable privileges, including those protecting attorney client communications and attorney work
product information. Use of this communication or its information without approval is prohibited.
Exhibit C
@ GORDON&REES
AMBER A. EKLOF SCULLY MANSUKHANl
ATTORNEYS AT LAW
° °
AEKL F@G RDO N REE 5 . c OM
275 BATTERY STREET. Sum: 2000
SAN FRANCISCO, CA 94111
PHONE: (415) 986-5900
Fs (415) 986-8054
VWVW.GORDONREES.CDM
August 7. 2018
VIA EMAIL & US MAIL
Fredrick A. Hagen
BERDING WEIL I
2175 N. California Blvd., Suite 500
Walnut Creek, CA 94596
l‘nagen@berding-weil.com
Re: Ali 'l'aghavi v. Slanford University,
et a].
Santa Clara County Superior Court, Case No. 17CIV04570
Dear Fred:
1 write as a follow up to your July 31, 2018 email designating Plaintiff’s deposition
transcript and video from July 30-31 as “Confidential” under the protective order. Pursuant to
Section 8 of the protective order, Stanford objects to your designation of the transcript and video
as confidential. If you intend to maintain the designation, it is your burden to do so in accordance
with the protective order and the California Rules of court.
Very truly yours,
GORDON REES SCULLY MANUSKHANI LLP
Amber A. Eklof
CC: Karen Kubin; David Zins
l l.‘ l 3mmxnmfi7h- )
Exhibit D
From: Amber Eklof [mailto:aeklof@grsm.com]
Sent: Wednesday, August 15, 2018 4:44 PM
To: Fredrick A. Hagen
Cc: kkubin@mofo.com; Emily L. Tetzel; Terri L. Nocco; Zins, David P.; Marcie Isom Fitzsimmons
Subject: RE: Taghavi v. Leland Stanford
Fred,
Icannot speak for Alticor's objections, but from Sta nford’s position, Plaintiff's deposition transcript does not fall within
any of the materials the parties agreed to designate as ”Confidential” under Section 1 ofthe stipulated protective order.
Consistent with Section 8 of the stipulated order and the California Rules of Court, it is your burden to identify the
specific basis for the designation consistent with the stipulated order. As such, blanket designation is unwarranted.
Kind regards,
Amber
AMBER A. EKLOF | Associate
GORDON 8L REES
SCULLY MANSUKHANI
275 Battery Street, Suite 2000
San Francisco, CA 94111
P: 415-986—5900 I F: 415-986-8054
aeklof@grsm.com
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Exhibit E
—-——-OriginalMessage —————
From: Kubin, Karen J. [mailtozKKubiaofocom]
Sent: Friday, August 17, 2018 1:14 PM
To: Fredrick A. Hagen; 'Amber Eklof‘
Cc: misom@grsm.com; Zins, David P.
Subject: RE: [EXT] Taghavi
Fred,
Further to my email below, which addressed your improper designation of the first two days of Mr. Taghavi's deposition
asconfidential, we hereby advise that it is Alticor's position the third day of his deposition, which you also designated as
confidential, is not entitled to confidential treatment either.
Karen
Karen J. Kubin
Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105
(0) 415—268-6168
(f) 415-268—7522
mailto:kkubin@_mofo.com
----- Original Message---—-
From: Kubin, Karen J.
Sent: Wednesday, August 01, 2018 8:30 AM
To: Fredrick A. Hagen; Amber Eklof
Cc: misom@grsm.com; Zins, David P. (DZins@mofo.com)
Subject: RE: [EXT] Taghavi
Fred,
Itrust you appreciate that in any motion practice that implicates Mr. Taghavi's deposition testimony, you will be called
upon to defend your designation of his testimony as confidential. Since none of it is, your effort to conceal the
testimony from public view will fail and the testimony, including Mr. Taghavi's testimony exposing his extraordinary
resume fraud, will be a matter of public record. Presumably, you have advised your client of that risk.
As always, feel free to contact me if there is any aspect of this matter you wish to discuss.
Preview
Fredrick A. Hagen, California Bar No. 196220 BERDING & WEIL LLP F I L EGGUNTY D SAN MATEO 2175 N. California Blvd, Suite 500 Walnut Creek, California 94596 AUG 0 2n Telephone: 925 ~83‘8—2090 2 Facsimile: 925—820—5592 fliagemwzberdingweilcom Attorneys for Plaintiff ALI TAGHAVI, an individual 17— GIV— 04570 DIS Declaration in Support SUPERIOR COURT OF THE STATE OF CALIFORNIA 1711111111 lllllllllllll!l_ IN AND FOR THE COUNTY OF SAN MATEO ALI TAGHAVI, an individual, No. 17CIV04570 11 Plaintiff, DECLARATION OF FREDRICK A. . 12 HAGEN IN SUPPORT OF PLAINTIFF’S vs. MOTION FOR PROTECTIVE ORDER 13 REGARDING DEPOSITIONS OF ALI THE LELAND STANFORD JUNIOR TAGHAVI 14 UNIVERSITY, a California nonprofit corporation, doing business as STANFORD Date: September 21, 2018 15 UNIVERSITY; ALTICOR, INC, a Michigan Time: 9:00 a.m. corporation; and DOES 1-10, inclusive, Dept: L&M 31H 16 ' Defendants. 17 / A3 18 I, Fredrick A. Hagen, hereby declare as follows: xva 19 1. I am an attorney with the law firm of Berding Weil LLP, | counsel of record for 20 Plaintiff Ali Taghavi. I have personal knowledge of the facts set forth in this declaration and 21 could competently testify to those facts if called upon to do so. 22 2. This case arises out of Defendant the Leland Stanford Junior University’s (“the 23 University”) termination of lVIr. Taghavi from the University’s School of Medicine. On October 24 4, 2017, Mr. Taghavi filed a complaint against the University for wrongful termination and against 25 Alticor, Inc. (“Amway”) for international interference with prospective economic advantage. 26 3. On July 30, 31, and August 8, 2018, the University and Amway deposed Mr. 27 Taghavi extensively. regarding confidential matters. Given that the parties had agreed to a 28 stipulated protective order, I did not prevent questions regarding this confidential information or -1- DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S BERDING &WEIL, LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI 1175 N Calilomia Blvd sun. son Walmn Creek. Canton-Ia 94556 suspend the deposition to seek a protective order. On multiple instances during the depositions, Mr. Taghavi testified to confidential matters regarding his finances, personnel files, work history, and confidential medical issues and records‘related to his prior employment, all of which are protected under his right to privacy under the California Constitution. For example, Mr. Taghavi OLA->035) discussed his personnel files from his post—termination employers, including compensation records and employment application documents, which include further confidential information such as \] third party references. Mr. Taghavi was also asked extensively about similar past employment history and records, including personnel files subpoenaed from past employers, containing similar confidential information, including confidential medical information. Mr. Taghavi also testified 10 regarding confidential information related to his employment with the University. A majority of 11 his testimony concerned such confidential matters. 12 4. On July 30, 2018, the'Parties filed a Stipulation and [Proposed] Protective Order 13 Regarding Confidential Information (“the Stipulation”). The Stipulation permits a party to 14 designate any document as confidential that the party “reasonably considers in good—faith to 15 contain information involving trade secrets, or confidential business or financial information, 16 including personal financial information about any party to this lawsuit, putative class members or 17 employee of any party to this lawsuit, information regarding any individual’s banking relationship 18 with any banking institution, including information regarding the individual’s financial 19 transactions or financial accounts, and any informatiOn regarding any party not otherwise available 2o to the public, subject to protection under Rules 2.550, 2.551, 2.580, 2.585, 8.160, and 8.490 of the 21 California Rules of Court or under other provisions of California law.” (Stipulation 1] l.) 22 5. In addition, “A party or non—party may designate information disclosed during a 23 deposition as ‘Confidential’ by so indicating in said responses or on the record at the deposition 24 and requesting the preparation of a separate transcript of such materia .” (Stipulation 1T 2.) “In 25 addition, a party may designate in writing, within thirty (30) days after receipt of said responses 26 or of the deposition transcript for which the designation is proposed, that specific pages of the 27 transcript and/or specific responses be treated as ‘Confidential Information.’ Any other party may 28 object to such proposal, in writing or on the record. Upon such objection, the parties shall -2- DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S BERDING 8. WEIL LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI 1175 N Clfilnmia'Elvd Suits 50!) Walnul Creek, Callfanila 94536 follow the procedures described in Paragraph 8.” (Stipulation 11 2.) N 6. According to Paragraph ‘8 of the Stipulation, “[i]f a party contends that any material is not entitled to confidential treatment, such party may at any time give written notice to the party or non—party who designated the material. The party or non-party who designated the material shall have twenty (20) days from the receipt of such written notice to apply to the Court for an \OooflmUl-hlfl order designating the material as confidential. The party seeking the order has the burden of establishing that the document is entitled to protection.” (Stipulation fl 8.) 7. On July 31, 2018, I emailed counsel for Defendants that he designated Mr. Taghavi’s three depositions, including the transcripts and videos, as confidential (“Designation 10 Notice”). (A true and correct copy of the Designation Notice is attached to this declaration as 11 Exhibit A.) 12 8. I also emailed a “meet and confer” email to counsel for Defendants on August 15, 13 2018. (A true and correct copy of the meet and confer email is attached to this declaration as 14 Exhibit B.) 15 9. Counsel for the University objected to the designation of the July 30-31 deposition 16 in a letter to me dated August 7, 2018 (“University Objection Letter”). Counsel for the University 17 objected to the designation for the August 8 deposition on August 15, 2018 (“University Objection 18 Email”). True and correct copies of the University Objection Letter and University Objection 19 Email is attached to this declaration as Exhibit C and Exhibit D, respectively.) 20 10. Counsel for Amway objected to the designation on August 1 and 17, 2018 21 (“Amway Objection Email”). A true and correct copy of the Amway Objection Email is attached 22 to this declaration as Exhibit E.) 23 11. Because counsel for both Defendants objected when I designated the deposition 24 materials as confidential, I filed this motion under the Stipulation fil 8. Mr. Taghavi seeks a 25 protective order that seals the depositions—including the transcripts and videos—from disclosure 26 to the public. 27 12. Neither the University nor Amway have provided a reason for making MI. 28 Taghavi’s deposition public, including the written deposition transcripts, the Videos taken of the _3_ DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAINTIFF’S BERDING & WEIL, LLF MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI 211s "Calilnmia and suits mu Walnut avuk. Callfomlz Miss deposition, or the exhibits to the deposition. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on August 20, 2018 Creek, California. Yahut L/ 4:. O\.U-. A IiiEdrick A. Hagen \] 00 \D 10 11 12 13 14 15 16 17 18 19 X:\Wdocs\8236\91\PLD\0094548 l .DOCX 20 21 22 23 24 25 26 27 28 DECLARATION OF FREDRICK A. HAGEN IN SUPPORT OF PLAIN TIFF’S BERDING &WEIL, LLP MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITIONS OF ALI TAGHAVI 1‘ 15 N California Blvd Suite 5013 Walnul Creek, Callfumia 94596 Exhibit A ----- Original Message—---- From: Fredrick A. Hagen [mailtotagen@berdjgweilcom] Sent: Tuesday, July 31, 2018 10:14 PM To: Amber Eklof; Kubin, Karen 1. Subject: [EXT] Taghavi Amber and Karen, This will confirm that I am designating Mr. Taghavi’s deposition transcript and video, etc., as confidential under the stipulated protective order. Thanks, Fredrick A. Hagen Sent from my iPhone This message may be confidential and privileged. Use or disclosure by anyone other than an intended addressee is prohibited. If you received this message in error, please delete it and advise the sender by reply email. Exhibit B From: Fredrick A. Hagen Sent: Wednesday, August 15, 2018 1:32 PM To: Amber Eklof (aeklof@grsm.com) Cc: kkubin@mofo.com; Emily L. Tetzel; Terri L. Nocco Subject: RE: Taghavi v. Leland Stanford Ms. Eklof, The purpose of this email is to meet and confer regarding your objection to designating the deposition of transcript for Ali Taghavi’s deposition as confidential, which includes transcripts and videos taken on July 30, July 31, and August 8, along with the attached exhibits. You provided no reason for objecting, so l am unable to meet and confer regarding anyjustification you may have. As you know, Mr. Taghavi was deposed extensively regarding private and confidential personnel and employment related matters, including Mr. Taghavi's confidential information and the confidential information of third parties. Further, there is no reason to make the deposition transcripts, videos or exhibits public at this or any time. Moreover, you and Amway have asserted blanket confidentiality for all documents produced since the parties signed the stipulated protective order, which includes numerous documents that are not confidential. So the standard you wish to impose on me you are not following. Forcing me to identify parts of the deposition that are less confidential and parts that are more confidential is just an attempt to make me do busy work. There is no reason to make any ofthe deposition public. Please withdraw your objection to making Mr. Taghavi’s deposition and related video and exhibits confidential so we can avoid the waste of part and judicial resources. Thanks, Fred Fredrick A. Hagen | Attorney fhagen@berding—weil.com 1 Profile 1 vCard BERDINGZWEIL . ATTORN EYS AT LAW CELEBRATING 3} YEARS OF EXCELLENCE WALNUT CREEK COSTA MESA SAN DIEGO 2175 N California Blvd. 575 Anton Blvd. 1660 Hotel Circle North Suite 500 Suite 1080 Suite 701 Walnut Creek Costa Mesa San Diego CA 94596 CA 92626 CA 92108 P 925.838.2090 P 714.429.0600 P 858.625.3900 F 925.820.5592 F 714.429.0699 F 858.525.3901 www.berdingwei|.com | Linkedln I Facebook This communication is intended to be protected by all applicable privileges, including those protecting attorney client communications and attorney work product information. Use of this communication or its information without approval is prohibited. Exhibit C @ GORDON&REES AMBER A. EKLOF SCULLY MANSUKHANl ATTORNEYS AT LAW ° ° AEKL F@G RDO N REE 5 . c OM 275 BATTERY STREET. Sum: 2000 SAN FRANCISCO, CA 94111 PHONE: (415) 986-5900 Fs (415) 986-8054 VWVW.GORDONREES.CDM August 7. 2018 VIA EMAIL & US MAIL Fredrick A. Hagen BERDING WEIL I 2175 N. California Blvd., Suite 500 Walnut Creek, CA 94596 l‘nagen@berding-weil.com Re: Ali 'l'aghavi v. Slanford University, et a]. Santa Clara County Superior Court, Case No. 17CIV04570 Dear Fred: 1 write as a follow up to your July 31, 2018 email designating Plaintiff’s deposition transcript and video from July 30-31 as “Confidential” under the protective order. Pursuant to Section 8 of the protective order, Stanford objects to your designation of the transcript and video as confidential. If you intend to maintain the designation, it is your burden to do so in accordance with the protective order and the California Rules of court. Very truly yours, GORDON REES SCULLY MANUSKHANI LLP Amber A. Eklof CC: Karen Kubin; David Zins l l.‘ l 3mmxnmfi7h- ) Exhibit D From: Amber Eklof [mailto:aeklof@grsm.com] Sent: Wednesday, August 15, 2018 4:44 PM To: Fredrick A. Hagen Cc: kkubin@mofo.com; Emily L. Tetzel; Terri L. Nocco; Zins, David P.; Marcie Isom Fitzsimmons Subject: RE: Taghavi v. Leland Stanford Fred, Icannot speak for Alticor's objections, but from Sta nford’s position, Plaintiff's deposition transcript does not fall within any of the materials the parties agreed to designate as ”Confidential” under Section 1 ofthe stipulated protective order. Consistent with Section 8 of the stipulated order and the California Rules of Court, it is your burden to identify the specific basis for the designation consistent with the stipulated order. As such, blanket designation is unwarranted. Kind regards, Amber AMBER A. EKLOF | Associate GORDON 8L REES SCULLY MANSUKHANI 275 Battery Street, Suite 2000 San Francisco, CA 94111 P: 415-986—5900 I F: 415-986-8054 aeklof@grsm.com vCa rd 2 Connectsmt [ [mlaware l L): iii -::F('.‘niumhm : Mary-laud l Massa. Michigan NJ'WJEYSGY | upw‘r’crk i North Carolina | Ohio , E Hunt: i Virginia I ‘.*J.3.;l'iingt~:m [ West Virginia | Wisconsin www.grsm.com Exhibit E —-——-OriginalMessage ————— From: Kubin, Karen J. [mailtozKKubiaofocom] Sent: Friday, August 17, 2018 1:14 PM To: Fredrick A. Hagen; 'Amber Eklof‘ Cc: misom@grsm.com; Zins, David P. Subject: RE: [EXT] Taghavi Fred, Further to my email below, which addressed your improper designation of the first two days of Mr. Taghavi's deposition asconfidential, we hereby advise that it is Alticor's position the third day of his deposition, which you also designated as confidential, is not entitled to confidential treatment either. Karen Karen J. Kubin Morrison & Foerster LLP 425 Market Street San Francisco, CA 94105 (0) 415—268-6168 (f) 415-268—7522 mailto:kkubin@_mofo.com ----- Original Message---—- From: Kubin, Karen J. Sent: Wednesday, August 01, 2018 8:30 AM To: Fredrick A. Hagen; Amber Eklof Cc: misom@grsm.com; Zins, David P. (DZins@mofo.com) Subject: RE: [EXT] Taghavi Fred, Itrust you appreciate that in any motion practice that implicates Mr. Taghavi's deposition testimony, you will be called upon to defend your designation of his testimony as confidential. Since none of it is, your effort to conceal the testimony from public view will fail and the testimony, including Mr. Taghavi's testimony exposing his extraordinary resume fraud, will be a matter of public record. Presumably, you have advised your client of that risk. As always, feel free to contact me if there is any aspect of this matter you wish to discuss.