EXHIBIT 7 

Case 6:20-cv-00477-ADA Document 110-8 Filed 08/18/21 Page 1 of 3
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Ramlakhan, Bevannie N.

From: Barry Shelton <bshelton@sheltoncoburn.com>

Sent: Wednesday, June 9, 2021 8:54 AM

To: mark waltfairpllc.com

Subject: RE: !! WSOU/Dell: Protective order issues

That’s good to hear. The Gibson Dunn folks will take it from here, as I’m headed up your way tomorrow morning for voir 

dire, with trial next week. 

From: mark waltfairpllc.com <mark@waltfairpllc.com> 

Sent: Wednesday, June 9, 2021 7:50 AM 

To: Barry Shelton <bshelton@sheltoncoburn.com> 

Subject: FW: !! WSOU/Dell: Protective order issues 

BTW, I have some traction on the issues we discussed in the PO. But they want a redline – because if you compare the 

PDF that was sent in the last email exchange on this topic with the redline we sent, there are changes that disregarded 

that the parties did not agree too. Regardless, we have traction. 

From: Barry Shelton <bshelton@sheltoncoburn.com> 

Sent: Tuesday, June 8, 2021 9:01 PM 

To: Jim Etheridge <jim@etheridgelaw.com>; Sabanoglu, Kyanna <KSabanoglu@gibsondunn.com>; *** GDC-Dell_WSOU 

<GDC-Dell_WSOU@gibsondunn.com> 

Cc: mark waltfairpllc.com <mark@waltfairpllc.com>; Ryan Loveless <ryan@etheridgelaw.com>; Travis Richins 

<travis@etheridgelaw.com> 

Subject: RE: !! WSOU/Dell: Protective order issues 

Jim, 

We are discussing the changes Mark and I negotiated with our clients and will get back to you with a redline soon. In the 

meantime, obviously we do not acquiesce in WSOU’s previous proposal, in the same way we did not take WSOU’s 

months of silence regarding the protective order as WSOU’s agreement. Does WSOU agree to the trial groupings and 

discovery limits I proposed to Mark on May 27, namely the following groupings with the OGP default discovery limits for 

one case applying to each grouping in the aggregate? 

Group 1: -475, -476, -477, -482 

Group 2: -473, -474, -478, -479 

Group 3: -480, -481, -485, -486 

Regards, 

Barry 

From: Jim Etheridge <jim@etheridgelaw.com> 

Sent: Tuesday, June 8, 2021 7:49 PM 

To: Barry Shelton <bshelton@sheltoncoburn.com>; Sabanoglu, Kyanna <KSabanoglu@gibsondunn.com>; *** GDCDell_WSOU <GDC-Dell_WSOU@gibsondunn.com> 

Cc: mark waltfairpllc.com <mark@waltfairpllc.com>; Ryan Loveless <ryan@etheridgelaw.com>; Travis Richins 

<travis@etheridgelaw.com>; Jim Etheridge <jim@etheridgelaw.com> 

Subject: !! WSOU/Dell: Protective order issues 

Case 6:20-cv-00477-ADA Document 110-8 Filed 08/18/21 Page 2 of 3
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Barry, 

As requested by Kyanna, we also ask that to the extent Dell has any edits to the WSOU proposed Protective Order, 

please make these changes with track changes. 

If we don’t hear back from you by Thursday, we will assume the parties are in agreement and we can submit WOSU’s 

last version to the court. 

Cordially, 

Jim 

From: Jim Etheridge <jim@etheridgelaw.com> 

Sent: Wednesday, June 2, 2021 7:18 PM 

To: Barry Shelton (bshelton@sheltoncoburn.com) <bshelton@sheltoncoburn.com> 

Cc: mark waltfairpllc.com <mark@waltfairpllc.com>; Ryan Loveless <ryan@etheridgelaw.com>; Jim Etheridge 

<jim@etheridgelaw.com> 

Subject: Re: WSOU/Dell: Protective order issues 

 

Barry,

Thank you for your email. To move this forward, can you (Dell) please send a proper redline 

against the last version we sent you.

That would be helpful in resolving the issues.

Jim

 

From: Barry Shelton <bshelton@sheltoncoburn.com> 

Sent: Wednesday, June 2, 2021 10:30 AM 

To: mark waltfairpllc.com <mark@waltfairpllc.com> 

Subject: WSOU/Dell: Protective order issues 

 

Mark, 

 

I hope you had a nice Memorial Day. Checking in to see if you have any feedback about the protective order issues we 

discussed last week. Thanks, 

 

Barry 

 

Barry K. Shelton | Partner 

Shelton Coburn LLP 

311 RR 620 S, Suite 205 

Austin, Texas 78734-4775 

T: (512) 263-2165 | F: (512) 263-2166 | M: (512) 517-9998 

bshelton@sheltoncoburn.com | www.sheltoncoburn.com

 

Case 6:20-cv-00477-ADA Document 110-8 Filed 08/18/21 Page 3 of 3