Expert Undertaking

• Author: Kenneth L. Dorsney
• Pages: 805-805

Expert Undertaking

[Date]

BY ELECTRONIC MAIL

[Name of Attorney for Defendant]

[Name of Counsel for Defendant]

[Address of Counsel for Defendant]

Re: Brand, Inc. v. Generic, Inc.,

C.A. No. 12-3456 (JDG)

Dear [Name of Attorney for Defendant]:

Pursuant to Paragraph 7 of the Protective Order entered in this litigation

[Cite], attached is a signed undertaking for [Name], Ph.D. (Exhibit _), as well as a copy

of [Name]’s curriculum vitae. He has reviewed and agreed to abide by the terms of the

Protective Order.

Please let us know if any defendant objects to Brand, Inc.’s disclosure of

Confidential Information or ATTORNEYS’ EYES ONLY Information to [Name]. If we

do not hear anything by [date], we will assume that there is no objection.

Sincerely,

[Name of Attorney for Plaintiff]

Attachments

cc: Counsel of Record (by e-mail w/ attachments)

805

A-24

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