Penobscot Building, Suite 1800
Detroit, Michigan 48226
Fax (313) 963-3572
February 29, 2000
When you originally so kindly agreed to lend your expertise, gratis, to our clients in the Northwest Airline's lawsuit against its flight attendants to win injunctive relief against a claimed holiday "sickout," none of us realized that the free speech issues raised by Northwest's demand for injunctive relief would be eclipsed by the privacy issues involved in Northwest's discovery demand to copy and search the union's and our clients' computer hard drives. Rather, you generously agreed to assist us because you found Northwest's discover demands to be so offensive to generally accepted limits on the scope of computer discovery. You were offended, as well, by the "David and Goliath" character of its confrontation.
What quickly followed your commitment to assist us in this case were several weeks of the most intense litigation, in which we often needed to -- and did -- turn to you repeatedly, at outrageous hours of the day and night, for your technical expertise. You unfailingly responded immediately to each such appeal for help, and unfailingly gave us valuable and needed technical advice. You offered to fly to Minneapolis for the hearing scheduled on February 14 and 15, 2000, to testify as and expert witness, if needed -- again, gratis. You made yourself available throughout this ordeal and never failed to be there for us when we needed your help.
On behalf of our clients and as their counsel, I want to thank you for your generosity in this litigation. We could not possibly have dealt with the technical aspects of Northwest's computer discovery demands without your help. In particular, your skill in explaining computer technicalities to computer idiots in a simple lay language and your foresight in sharing with us your experience in computer discovery practices were invaluable to us. Our work together in this case has undoubtedly already increased public awareness of some important computer privacy issues. With your continuing assistance, we hope to win some measure of judicial protection against the sort of discovery abuses that occurred in this case
Very truly yours,