Smart meter security audit plans schedules proposals contracts discussion results (Seattle)
| Submitted | April 12, 2016 |
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Communications
From: Phil Mocek
To Whom It May Concern:
Pursuant to RCW Ch. 42.56 (Public Records Act), I hereby request the following records:
Plans for, schedules of, policies dictating the performance of, requests for proposals to, contracts for, discussion of, and results of all security audits performed of "smart meter" devices (remotely-addressable electrical meters sometimes referred to as "advanced metering infrastructure"), along with metadata. These devices are designed to replace traditional electric meters. They contain sensors that monitor activities inside subscribers' premises and automatically communicate information collected by those sensors to machines in remote locations.
I also request that, if appropriate, fees be waived as I believe this request is in the public interest. The requested documents will be made available to the general public free of charge as part of the public information service at MuckRock.com, processed by a representative of the news media/press and is made in the process of news gathering and not for commercial usage.
In the event that fees cannot be waived, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 5 business days, as the statute requires.
Sincerely,
Phil Mocek
From: MuckRock.com
To Whom It May Concern:
I wanted to follow up on the following Freedom of Information request, copied below, and originally submitted on April 12, 2016. Please let me know when I can expect to receive a response, or if further clarification is needed.
Thanks for your help, and let me know if further clarification is needed.
From: Gominger, Natalie
Mr. Mocek,
I am in-house counsel to Sensus USA Inc. and I am wondering if you are available to briefly discuss your public records request for proposals submitted for "SCL-RFP-3404, Advanced Metering Infrastructure," as our company's proposal falls under your request.
Please call me at your convenience or provide a time and phone number where I might be able to reach you.
All the best,
Natalie
Natalie Gominger | Legal Counsel
8601 Six Forks Road | Suite 700 | Raleigh, NC 27615 USA
T: 919-376-2638
natalie.gominger@sensus.com<mailto:natalie.gominger@sensus.com>| www.sensus.com<http://www.sensus.com/>
From: Seattle City Light
Dear Mr. Mocek,
I am writing in regards to your public disclosure request for:
“Plans for, schedules of, policies dictating the performance of, requests for proposals to, contracts for, discussion of, and results of all security audits performed of "smart meter" devices (remotely-addressable electrical meters sometimes referred to as "advanced metering infrastructure"), along with metadata. These devices are designed to replace traditional electric meters. They contain sensors that monitor activities inside subscribers' premises and automatically communicate information collected by those sensors to machines in remote locations.”
We have provided third party notice to the vendors regarding the release of the RFP responses and the contract. A number of vendors object to the release of pricing and trade secret information. In the interest of resolving this objection, I will provide you with redacted versions of the RFP responses for your review. You have already received a redacted version of the contract on April 19, 2016.
If you are willing to accept redacted versions of the RFP responses and the contract, please let me know by Friday May 13, 2016; otherwise, I will provide the vendors the opportunity to file a court injunction to prohibit disclosure.
The RFP responses are too large to transmit by email. I can transmit the redacted records to you on a CD and waive the fees. Please provide me with a mailing address so that I may mail the CD to you.
Please get back to me as soon as you can and let me know how you would like to proceed.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER’S TEAM
From: SCL_CityLight_PDR
Dear Mr. Mocek,
I am writing in regards to your public disclosure request for:
"Plans for, schedules of, policies dictating the performance of, requests for proposals to, contracts for, discussion of, and results of all security audits performed of "smart meter" devices (remotely-addressable electrical meters sometimes referred to as "advanced metering infrastructure"), along with metadata. These devices are designed to replace traditional electric meters. They contain sensors that monitor activities inside subscribers' premises and automatically communicate information collected by those sensors to machines in remote locations."
We have provided third party notice to the vendors regarding the release of the RFP responses and the contract. A number of vendors object to the release of pricing and trade secret information. In the interest of resolving this objection, I will provide you with redacted versions of the RFP responses for your review. You have already received a redacted version of the contract on April 19, 2016.
If you are willing to accept redacted versions of the RFP responses and the contract, please let me know by Friday May 13, 2016; otherwise, I will provide the vendors the opportunity to file a court injunction to prohibit disclosure.
The RFP responses are too large to transmit by email. I can transmit the redacted records to you on a CD and waive the fees. Please provide me with a mailing address so that I may mail the CD to you.
Please get back to me as soon as you can and let me know how you would like to proceed.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
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image001
From: MuckRock
Hi there,
The appropriate address for this particular request is now:
MuckRock
DEPT MR 10378
411A Highland Ave
Somerville, MA 02144-2516
From: SCL_CityLight_PDR
Dear Mr. Mocek,
Thank you for providing me with a mailing address.
Are you willing to accept redacted bids?
Please let me know.
Thanks,
Stacy
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
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image001
From: SCL_CityLight_PDR
Dear Mr. Mocek,
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image001
From: Phil Mocek
Dear Ms. Irwin,
Your agency's program of replacing A) devices which measure total energy usage, provide an interface consisting of analog dials that move proportionately to energy usage (thus as visible and comprehensible to ratepayers as a clock on the wall), which have for decades been effectively sampled with frequency sufficient for accurately billing ratepayers, with B) devices with unspecified and unverifiable sensors that monitor activity inside of private property and can communicate collected information in real-time to unspecified machines in remote locations, the workings of which are obscured from ratepayers, with interfaces used by your agency that require specialized equipment and are thus completely unavailable to ratepayers for personal use or monitoring and verification of information communicated, is already shrouded in secrecy and seemingly proceeding despite repeated voicing of public concern and complete lack of public justification of expense.
Please redact from the records I requested almost a month ago only that which you are required by law to redact.
Cordially,
Phil Mocek
From: SCL_CityLight_PDR
Dear Mr. Mocek,
Because you will not accept redacted bids, I am allowing our vendors some time to obtain a court injunction to prohibit release. I now estimate records will be ready for you by May 26, 2016. This time should be sufficient for the city to allow the subjects of your request time to enjoin the release, if they so desire.
Please feel free to contact me if you have any questions.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
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image001
From: Amy Akers
Good Afternoon -
Attached please find correspondence from Attorney Eric Christensen in the above referenced matter. Hard copies will follow via U.S. Mail. If you have any questions please do not hesitate to contact our office.
Thank you,
CH& | Amy Akers
Legal Assistant
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4490 | f:206-587-2308
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: MuckRock.com
To Whom It May Concern:
I'm following up on the following Public Records request, copied below, and originally submitted on April 12, 2016. You had previously indicated that it would be completed on May 17, 2016. I wanted to check on the status of my request, and to see if there was a new estimated completion date.
Thanks for your help, and let me know if further clarification is needed.
From: Eric Christensen
Ladies & Gentlemen,
Please be advised that, this afternoon, we filed a lawsuit in King County Superior Court seeking declaratory and injunctive relief, and damages, in connection with a Public Records Act request submitted by Mr. Mocek and posted on MuckRock.com. Please be further advised that we will seek a Temporary Restraining Order at 9:00 a.m., Wednesday, May 25, in Room W-325 of the King County Superior Court, 516 Third Ave., Seattle, Washington.
For your information, I have attached a copy of the complaint in this proceeding, the Motion for Temporary Restraining Order, and three supporting affidavits.
CH& | Eric Christensen
Attorney
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4451 | f:206-587-2308 | Bio<http://www.cairncross.com/ourpeople/attorneys/89/Eric-Christensen>
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: Eric Christensen
Please find the attached motion for temporary restraining order.
CH& | Eric Christensen
Attorney
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4451 | f:206-587-2308 | Bio<http://www.cairncross.com/ourpeople/attorneys/89/Eric-Christensen>
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: Seattle City Light
An interim response, stating the request is being processed.
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Exhibit I - Part 2 02826787.PDF
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Exhibit I - Part 3 02886889.PDF
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Exhibit I - Part 1 02822294.PDF
There are too many files to display on this communication. See all files
From: Eric Christensen
For you information, I am attaching my declaration and the proposed order for a temporary restraining order, which complete the documents we will present tomorrow in support of our motion for a temporary restraining order.
Because the attachments to my declaration are voluminous, I have not tried to email them. They can be downloaded through this Sharefile link: R:\CaseData\012715 - Landis & Gyr\-0002 Mocek PRA Request\Exhibits to ELC Decl re TRO Motion<file:///\\VMLIT-SUPPORT\Litigation%20Support\CaseData\012715%20-%20Landis%20&%20Gyr\-0002%20Mocek%20PRA%20Request\Exhibits%20to%20ELC%20Decl%20re%20TRO%20Motion>
Please contact me if you have any problems with the download process.
CH& | Eric Christensen
Attorney
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4451 | f:206-587-2308 | Bio<http://www.cairncross.com/ourpeople/attorneys/89/Eric-Christensen>
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: Eric Christensen
Correction: here is the Sharefile link: https://cairncross.sharefile.com/d-sb2526471312430c9.
CH& | Eric Christensen
Attorney
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4451 | f:206-587-2308 | Bio<http://www.cairncross.com/ourpeople/attorneys/89/Eric-Christensen>
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: Shannon Jost
Sent via Email: morisy@gmail.com<mailto:morisy@gmail.com>; requests@muckrock.com<mailto:requests@muckrock.com>; Jessica.Nadelman@seattle.gov<mailto:Jessica.Nadelman@seattle.gov>
Dear Messrs. Mocek and Morisy, and Ms. Nadelman:
Please be advised that Ericsson, Inc. has filed the attached Complaint in King County Superior Court and will be filing its Motion for Temporary Restraining Order and for Order to Show Cause Regarding Preliminary Injunction ("TRO Motion") in the above-referenced matter, seeking declaratory and injunctive relief, in connection with a Public Records Act request submitted by Mr. Mocek, MuckRock Foundation and posted on MuckRock.com.
Please take notice that Ericsson's Motion for Temporary Restraining Order and Order to Show Cause Regarding Preliminary Injunction will be heard at 9:00 am PT on Wednesday, May 25, 2016, in Room W-325 of the King County Superior Court, 516 Third Ave., Seattle, Washington.
Attached please find:
* Complaint for Injunctive and Declaratory Relief;
* Summons to Seattle City Light;
* Summons to Phil Mocek;
* Summons to MuckRock Foundation;
* Order Setting Civil Case Schedule;
* Case Information Sheet;
* Note for Motion;
* Plaintiff's Motion for Temporary Restraining Order and for Order to Show Cause Regarding Preliminary Injunction;
* Declaration of Shannon M. Jost;
* Declaration of Mark Burke;
* Proposed Temporary Restraining Order and Order to Show Cause.
Service copies of the attached documents will be forthcoming.
Shannon M. Jost
Shareholder
Stokes Lawrence, P.S. - Realizing your vision.
1420 Fifth Avenue, Suite 3000 | Seattle, WA 98101-2393
Tel.: (206) 892-2124 | Fax: (206) 464-1496
Email: shannon.jost@stokeslaw.com | Web: www.stokeslaw.com
This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee(s) named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.
There are too many files to display on this communication. See all files
From: Phil Mocek
Dear Ms. Irwin,
You misrepresented my position in your e-mail of May 11 . Nothing I have communicated to you indicates that I "will not accept redacted bids." In fact, in my e-mail to you earlier that day, I explicitly requested that you redact these public records as the law requires.
Your agency does not get to determine what is good for the public to know what what is not good for us to know. Outsourcing the design of public infrastructure does not relieve your agency--part of our municipal government--from its duty to provide public records as requested. Nor do your vendors get to determine what is good for the public to know and what is not good for us to know. That City Light are charging full-steam ahead with plans to foist a system with great potential to negatively affect the privacy and security of City Light ratepayers upon us strengthens the need for public oversight. Your resistance to providing details of your plan suggests a bad-faith effort to keep the public in the dark.
I reiterate my request for you to redact any information that is exempt from disclosure under the Public Records Act and provide the non-exempt portions of those records.
Cordially,
Phil Mocek
From: Nadelman, Jessica
Mr. Mocek,
I represent the City of Seattle and City Light in this matter. By way of clarification, I wanted to explain the City's position regarding release of these records and see if we can reach some resolution. The vendors believe that some information contained within the bids are company trade secrets and valuable formula. The City is not in a position to assert exemptions on behalf of private companies for this type of information because we lack the technical background to determine which information is exempt as trade secrets.
Therefore, at this point, the options are as follows:
1) You have been provided redacted copies of each of the bids. The redactions are based on the vendors' determination as to what is exempt as a trade secret. You will note that much of the redacted information concerns pricing and technical data. If you are willing to agree that these redactions are acceptable and that your request is satisfied as to the bid records, we can close your request and will not need to litigate that issue.
2) In the alternative, if you are unwilling to accept the redacted versions, the litigation will proceed. All of the vendors intend to seek injunctions to prevent release of unredacted records.
To be clear, the only way that the City will provide redacted records for trade secret exemptions is through a court order or a written agreement from a requester.
Please confirm in writing as to your preference for proceeding with this matter. You may also contact me by phone at the number below if you would like further clarification.
Jessica
[image001]
Jessica Nadelman
Assistant City Attorney
Seattle City Attorney's Office
Civil Division
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7097
Phone: 206-386-0075
FAX: 206-684-8284
jessica.nadelman@seattle.gov<mailto:Your.email@seattle.gov>
CONFIDENTIALITY STATEMENT: This message may contain information that is protected by the attorney-client privilege, the attorney work product doctrine, or by other confidentiality provisions. If this message was sent to you in error, any use, disclosure, or distribution of its contents is prohibited. If you receive this message in error, please contact me at the telephone number or e-mail address listed above and delete this message without printing, copying, or forwarding it. Thank you.
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image003
From: Nadelman, Jessica
My mistake. I understand that you have not yet received the redacted bids, however, the City can provide copies to you if you are interesting in pursuing this option.
Thank you,
Jessica
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image001
From: Shannon Jost
Sent via Email: morisy@gmail.com<mailto:morisy@gmail.com>; requests@muckrock.com<mailto:requests@muckrock.com>; Jessica.Nadelman@seattle.gov<mailto:Jessica.Nadelman@seattle.gov>
Dear Messrs. Mocek and Morisy, and Ms. Nadelman:
Please be advised that Ericsson, Inc. will file today the attached Motion for Preliminary Injunction.
Please take notice that Ericsson's Motion for Preliminary Injunction will be heard at 10:00 am PT on Friday, June 3, 2016, Before Judge Theresa Doyle, at the King County Superior Court, 516 Third Ave., Seattle, Washington.
Attached please find:
* Plaintiff's Motion for Preliminary Injunction;
* Second Declaration of Shannon M. Jost;
* Notice of Motion;
* Proposed Preliminary Injunction Order.
Service copies of the attached documents will be forthcoming.
Shannon M. Jost
Shareholder
Stokes Lawrence, P.S. - Realizing your vision.
1420 Fifth Avenue, Suite 3000 | Seattle, WA 98101-2393
Tel.: (206) 892-2124 | Fax: (206) 464-1496
Email: shannon.jost@stokeslaw.com<mailto:shannon.jost@stokeslaw.com> | Web: www.stokeslaw.com<http://www.stokeslaw.com>
This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee(s) named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.
From: Eric Christensen
Ladies and Gentlemen,
The King County Superior Court this morning granted the attached Temporary Restraining Order, which prohibits the City of Seattle from releasing the protected materials of Plaintiffs Landis+Gyr Technology, Sensus USA, and Trilliant Networks pending further action of the Court.
From: Allen Estes
FYI
From: Allen Estes
FYI
From: Allen Estes
FYI
From: Allen Estes
FYI
From: Allen Estes
FYI
From: Allen Estes
Ms. Nadelman, Mr. Morisy and Mr. Mocek,
My name is Allen Estes. I am counsel of record for Elster Solutions, LLC. I understand that you represent Seattle City Lights, MuckRock Foundation, Inc. and Phil Mocek respectively. I am writing to you to advise each of you that Elster has moved for a TRO in the United States District Court for the Western District of Washington at Seattle. Attached please find Elster’s Complaint for Injunctive Relief, Motion for Temporary Restraining Order and to Show Cause, Memorandum in Support of Motion for Temporary Restraining Order, Proposed Order Granting Temporary Restraining Order and the Declaration of Robert Henes. I will send you copies of my Declaration in Support of this Motion in a separate email. I will also send you a confirmation of filing once I receive it from the Court. You will all be served pursuant to the code, but I wanted to provide you courtesy copies of the moving papers so that you are aware that Elster has sought a TRO in Federal Court and to advise each of you to cease and desist from any publication or production of Elster’s Proposal which is at issue in the attached papers until the Court rules on the Motion.
Please contact me if you have any questions or comments regarding this matter.
Best Regards,
Allen Estes
________________________________
Allen W. Estes, III | Partner
GORDON & REES<http://www.gordonrees.com>
SCULLY MANSUKHANI
701 Fifth Avenue, Suite 2100
Seattle, WA 98104
D: 206-695-5127 | P: 206-695-5100 | F: 206-689-2822
275 Battery Street, Suite 2000
San Francisco, CA 94111
P: 415-986-5900 | F: 415-986-8054
aestes@gordonrees.com<mailto:aestes@gordonrees.com>
vCard<http://vcard.gordonrees.com/vcard.cfm?card=aestes> | Bio<http://www.gordonrees.com/lawyers/a/allen-w-estes>
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From: Allen Estes
FYI
From: Allen Estes
Mr. Nadelman, Mr. Morisy and Mr. Mocek,
Attached please find a courtesy copy of my Declaration which was filed in the United States District Court for the Western District of Washington in Support of Elster’s Motion for a temporary Restraining Order. As I stated in my earlier email, you will each receive formal service of the documents which I provided as a courtesy to you tonight as soon as may be perfected thereafter under the applicable law.
Please cease and desist from the publication or dissemination of Elster’s Proposal which is the subject of the Motion for temporary Restraining Order until after the Court has ruled upon the same.
Thank you for your anticipated cooperation in this matter. Please let me know if you have any questions regarding this matter.
Best Regards,
Allen
________________________________
Allen W. Estes, III | Partner
GORDON & REES<http://www.gordonrees.com>
SCULLY MANSUKHANI
701 Fifth Avenue, Suite 2100
Seattle, WA 98104
D: 206-695-5127 | P: 206-695-5100 | F: 206-689-2822
275 Battery Street, Suite 2000
San Francisco, CA 94111
P: 415-986-5900 | F: 415-986-8054
aestes@gordonrees.com<mailto:aestes@gordonrees.com>
vCard<http://vcard.gordonrees.com/vcard.cfm?card=aestes> | Bio<http://www.gordonrees.com/lawyers/a/allen-w-estes>
Alabama • Arizona • California • Colorado • Connecticut • Florida • Georgia
Illinois • Maryland • Massachusetts • Missouri • Nevada • New Jersey • New York
North Carolina • Ohio • Oregon • Pennsylvania • South Carolina • South Dakota
Texas • Virginia • Washington • Washington, D.C. • West Virginia
www.gordonrees.com<http://www.gordonrees.com>
________________________________
Alabama * Arizona * California * Colorado * Connecticut * Florida * Georgia * Illinois * Maryland * Massachusetts * Missouri * Nevada * New Jersey * New York * North Carolina * Ohio * Oregon * Pennsylvania * South Carolina * South Dakota * Texas * Virginia * Washington * Washington, DC * West Virginia
This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies.
GORDON & REES LLP
http://www.gordonrees.com<http://www.gordonrees.com/>
From: Allen Estes
Ms. Nadelman, Mr. Morisy and Mr. Mocek,
Below please find the case number for Elster Solutions, LLC v. City of Seattle et. al.
Please let me know if you have any questions.
Allen
________________________________
Allen W. Estes, III | Partner
GORDON & REES<http://www.gordonrees.com>
SCULLY MANSUKHANI
701 Fifth Avenue, Suite 2100
Seattle, WA 98104
D: 206-695-5127 | P: 206-695-5100 | F: 206-689-2822
275 Battery Street, Suite 2000
San Francisco, CA 94111
P: 415-986-5900 | F: 415-986-8054
aestes@gordonrees.com<mailto:aestes@gordonrees.com>
vCard<http://vcard.gordonrees.com/vcard.cfm?card=aestes> | Bio<http://www.gordonrees.com/lawyers/a/allen-w-estes>
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From: Alicia Cason
Good afternoon,
Attached please find a signed copy of the Temporary Restraining Order and Order to Show Cause regarding the above-referenced matter. Please note this copy is double-sided.
This document is also included in hard copy in the service package you have received or will be receiving via messenger.
Thank you,
Alicia
From: Howard, Greg
Counsel and Parties,
Please see the notice of reassignment to Judge William Downing.
You should contact that court about potential scheduling issues related to the pending motion.
Sincerely,
Greg S. Howard,
Bailiff to the Honorable Laura C. Inveen
King County Superior Court
516 3rd Avenue, Rm W864
Seattle, WA 98104
greg.howard@kingcounty.gov<mailto:greg.howard@kingcounty.gov>
Please note the court phone number has recently changed to: (206) 477-1617
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2016-05-16 LANDIS 16-2-12149-7
From: Reese, Ricki
Good afternoon:
As it so happens we have that date and time open due to a continuance of a trial date of an asbestos case and multiple motions were noted for that morning. We'll await the motion paperwork from Judge Inveen's court and the response and replies should be directed attention to Judge Downing. We're located in the downtown courthouse on the 7th floor in courtroom E-762.
Ricki
From: Reese, Ricki
I'm re-sending this as the email bounced back from Ms. Perry...
Ricki
From: Reese, Ricki
And, apparently there has been a change of counsel on behalf of the City so I'm assuming a Notice of Appearance will be filed shortly...
Ricki
From: Allen Estes
Jessica,
Attached please find the Order from Judge Robert Lasnick of the United States District Court for the Western District at Seattle GRANTING Elster’s TRO. Please follow the Order and do not release any of Elster’s documents which are the subject of this Order.
Please call me if you have any questions.
Best Regards,
Allen
________________________________
Allen W. Estes, III | Partner
GORDON & REES<http://www.gordonrees.com>
SCULLY MANSUKHANI
701 Fifth Avenue, Suite 2100
Seattle, WA 98104
D: 206-695-5127 | P: 206-695-5100 | F: 206-689-2822
275 Battery Street, Suite 2000
San Francisco, CA 94111
P: 415-986-5900 | F: 415-986-8054
aestes@gordonrees.com<mailto:aestes@gordonrees.com>
vCard<http://vcard.gordonrees.com/vcard.cfm?card=aestes> | Bio<http://www.gordonrees.com/lawyers/a/allen-w-estes>
Alabama • Arizona • California • Colorado • Connecticut • Florida • Georgia
Illinois • Maryland • Massachusetts • Missouri • Nevada • New Jersey • New York
North Carolina • Ohio • Oregon • Pennsylvania • South Carolina • South Dakota
Texas • Virginia • Washington • Washington, D.C. • West Virginia
www.gordonrees.com<http://www.gordonrees.com>
________________________________
Alabama * Arizona * California * Colorado * Connecticut * Florida * Georgia * Illinois * Maryland * Massachusetts * Missouri * Nevada * New Jersey * New York * North Carolina * Ohio * Oregon * Pennsylvania * South Carolina * South Dakota * Texas * Virginia * Washington * Washington, DC * West Virginia
This email communication may contain CONFIDENTIAL INFORMATION WHICH ALSO MAY BE LEGALLY PRIVILEGED and is intended only for the use of the intended recipients identified above. If you are not the intended recipient of this communication, you are hereby notified that any unauthorized review, use, dissemination, distribution, downloading, or copying of this communication is strictly prohibited. If you are not the intended recipient and have received this communication in error, please immediately notify us by reply email, delete the communication and destroy all copies.
GORDON & REES LLP
http://www.gordonrees.com<http://www.gordonrees.com/>
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160526 TRO
From: SCL_CityLight_PDR
Dear Mr. Mocek,
Pursuant to your public disclosure request dated April 12, 2016 for "Plans for, schedules of, policies dictating the performance of, requests for proposals to, contracts for, discussion of, and results of all security audits performed of "smart meter" devices (remotely-addressable electrical meters sometimes referred to as "advanced metering infrastructure"), along with metadata," I am mailing you a CD today that contains the requested proposals. The proposals for Sensus USA, Trilliant Networks, and Landis+Gear, Technology will be in the redacted version per the temporary restraining order that was signed on May 25, 2016. I will send the Ericsson and Elster Solutions bids to you sometime next week.
As a courtesy, we are waiving all fees. I will mail the CD to the following address as you requested:
MuckRock
DEPT MR 10378
411A Highland Avenue
Somerville, MA 02144-2516
Please feel free to contact me if you have any questions.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
-
image001
From: Nadelman, Jessica
This is a new case (filed a few days ago) and I will be filing a notice of appearance shortly. Mary Perry is not involved in this case.
Thank you,
Jessica
[image001]
Jessica Nadelman
Assistant City Attorney
Seattle City Attorney's Office
Civil Division
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7097
Phone: 206-386-0075
FAX: 206-684-8284
jessica.nadelman@seattle.gov<mailto:Your.email@seattle.gov>
CONFIDENTIALITY STATEMENT: This message may contain information that is protected by the attorney-client privilege, the attorney work product doctrine, or by other confidentiality provisions. If this message was sent to you in error, any use, disclosure, or distribution of its contents is prohibited. If you receive this message in error, please contact me at the telephone number or e-mail address listed above and delete this message without printing, copying, or forwarding it. Thank you.
-
image001
From: Seattle City Light
A copy of documents responsive to the request.
There are too many files to display on this communication. See all files
From: Reese, Ricki
Thank you,
Ricki
-
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From: SCL_CityLight_PDR
Dear Mr. Mocek,
Attached please find a redacted version of the Landis+Gyr's Managed Service System report previously released to you on April 19, 2016. In the attached report, Landis+Gyr has redacted information about its computer security system as well as details about the physical safeguards employed at Landis+Gyr's Network Operations Center. Landis+Gyr views these details as trade secrets protected under the Washington Uniform Trade Secret Act, RCW Ch. 19.108, as well as computer security information protected from public disclosure under RCW 42.56.420. As you are aware, Landis+Gyr has filed an injunction action seeking to protect this information from disclosure.
Please let me know if you have any questions.
Regards,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
From: Amy Akers
Good Afternoon -
Attached please find the Supplemental Declaration of Eric Christensen filed today in the above referenced matter. Due to the volume of the exhibits, hard copies will not follow. Separate links to download Exhibits A through D will follow this email. Please let us know if you have any trouble with the links.
Thank you,
CH& | Amy Akers
Legal Assistant
Cairncross & Hempelmann
524 Second Avenue | Suite 500 | Seattle, WA 98104-2323
d:206-254-4490 | f:206-587-2308
This email message may contain confidential and privileged information. Any unauthorized use is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Please be advised that if you use a public or employer-provided computer or workplace device or system, then there is a risk that your email correspondence may be disclosed to your employer or other third party.
From: Amy Akers
Good Afternoon –
Please see the link to download Exhibit A to the Supplemental
Declaration of Eric Christensen
filed today in the above referenced matter. Due to the
volume of the documents hard copies will not follow. Please let
us know if you
have any trouble with the link.
Thank you,
Amy Akers, Legal Assistant
The following files are attached to this message:
- 0.0_Sensus Table of Contents for RFP SCL 3404-FINAL.pdf (25.5 KB), Checksum: 0b099c2edc9bc67035879907f3b2369272a086c9
- 1.0_Cover Letter-FINAL.pdf (35 KB), Checksum: 1bd5420009446fe02ae865e1f87ebc77d9236bee
- 2.0_Legal Name Verification-FINAL.pdf (51.3 KB), Checksum: 7e2e02d70c8440f26b30e9bacd6705e0476ca43e
- 3.0_Vendor Questionniare-FINAL.pdf (86.9 KB), Checksum: 1430a2fecf7570aff578e7f716dfddd91cd1ada2
- 4.0_Minimum Qualifications-FINAL_Redacted.pdf (22.1 KB), Checksum: e983d5f74c5ac792c1b37a77449c2dc36a16524c
- 5.0_Seller Certification-FINAL.pdf (161 KB), Checksum: ceeaa1ee2092469a2314aae14ff47b0245dcef50
- 6.0_Proposed Solution-Settlement_Redacted.pdf (75.1 KB), Checksum: a23a7a815005138749c52023024db9dade46a478
- 7.0_Coverage and Capacity Plan-Settlement_Redacted.pdf (45.9 KB), Checksum: 0c3ddfc95a03a02b6085f12e1e13de66f911a573
- 8.0_System Recommendations-Settlement_Redacted.pdf (107 KB), Checksum: 102c3377021d53d83250b97bb0c3e2aaeb0c7ec6
- 9.0_Customer References-Settlement_Redacted.pdf (28.3 KB), Checksum: 1081b00eba79bd6e3b706a94a720a59c0340f8c9
- 10.0_Project Team-Settlement_Redacted.pdf (177 KB), Checksum: 2c66f0138af98477cde8f0ca115b584a6880020d
- 11.0_Project Implementation Metholodogy-FINAL.pdf (27.2 KB), Checksum: f69e2c2461b9cdda52db7a64ae69612a8f728d13
- 12.0_Standard Hardware Warranty-FINAL.pdf (11 KB), Checksum: 8b7893244650eecf3a1ab463e05528caee31a3ef
- 13.0_Standard Software License including Software Maintenance Agreement-FINAL.docx (134 KB), Checksum: 4ff8fe42d0fcc4cc9632bab0d54492010c4ad7ce
- 14.0_Standard Statement of Work-FINAL.pdf (141 KB), Checksum: dee98872454ef295521011457c3badaf4aba2035
- 15.0_Solution Requirements Compliance_Requested Attachments-FINAL_Redacted.pdf (154 KB), Checksum: f5812ead7037cad7cb00ccff1d9808e8fa4979c2
- 15.0_Solution Requirements Compliance-FINAL-Redacted.xlsx (247 KB), Checksum: c42c3ba1130b01b858926a185bdf0e6616e3470e
- 16.0_Pricing Response-FINAL.pdf (10.4 KB), Checksum: 6d16fb7a7539adbd8454f448beac7b41fb150048
- 17.0_Outsourced, or Managed, Services Proposal-FINAL.pdf (45.9 KB), Checksum: 8cb9ddde6301cd4763bbf3a4caf751d0873bda40
- 18.0_City Wide Wi-Fi Network-FINAL.pdf (10.6 KB), Checksum: 8a4bd1d31f9123b437acbe147ff27f0901f6444b
- 19.0_Acceptance & Exceptions to City Contract-FINAL.docx (135 KB), Checksum: c2879810757a3455bc053a53b4ff4fd432b8737c
- A_Sensus Inclusion Plan-FINAL.doc (94 KB), Checksum: 7fa806f0a7ff11e4fe63668a42ef5930281bbb9a
- B_Project Team Resumes-Settlement_Redacted.pdf (1000 KB), Checksum: 25bc6e8608d990f6804660e051eaea57e18d6915
- Cost Proposal Cover Letter-FINAL_Redacted.pdf (561 KB), Checksum: dce8dd7df6620ab3de01b1f91b11a67cf1d5e55a
- D_Sensus General Limited Warranty-FINAL.pdf (63.3 KB), Checksum: c9df109d30a53cd1ca0fddf87260de8685fd7f5b
- E_2014 Sensus Utility Conference - Master Program-FINAL.pdf (11.5 MB), Checksum: 347d0eaa9a4568f53a6918effdcf036509f168ed
- F_RNI System Administration (E31SP4)-FINAL.pdf (151 KB), Checksum: a6e32b242671f48554d186a692dcfb0a3ee95084
- G_RNI System Operations (E31SP4)-FINAL.pdf (149 KB), Checksum: 28bb14e99589e969a0b58d652d1a71c38b07ee13
- H_Sensus Customer Support Procedures-FINAL.pdf (275 KB), Checksum: 7a5b57df1f44e6175cfbd5cc00a8d4b32bc49c11
- I_iConA Device Type 50 Alarms Quick Guide-FINAL_Redacted.pdf (316 KB), Checksum: 0c8daef94f814b17e6ef0f4f76db1aed62f896b4
- J_Elster A3 Device Type 49 Alarms-FINAL.pdf (311 KB), Checksum: 71eb632d122bde40a9e994da629ba341c5b7a3a5
- K_Sensus MTBF for iConA-_Settlement_Redacted.pdf (180 KB), Checksum: 21ef26edf03e177c5514075b215f67931aea3d6d
- L_AquaSense Water Meter and Ancillaries Compatibility List-FINAL.pdf (57.8 KB), Checksum: ca87d450f052c70b9ef241aa18dbfa5d19cd48db
- M_iPERL datasheet-FINAL.pdf (333 KB), Checksum: 053881aee9548370f73bd5f4fb262afcc0118bce
- N_MPE_Calculations_for_FlexNet-FINAL_Redacted.pdf (75.5 KB), Checksum: 8b362623b83c44e9d209d7831c2b46a3c8e73d36
- O_PIN-RNI-3 1-SP4 PS1 Announcement-FINAL_Redacted.pdf (147 KB), Checksum: 6ebb3cf86f05ad1a33b4795869e33ed839fba8ee
- P_Sensus Distribution Automation Control Devices-FINAL.pdf (1.44 MB), Checksum: 3cee144514df97121fbedd30b7c031ed95ccb17f
- Q_Device Manager 3.1 SP4 User Guide-FINAL_Redacted.pdf (557 KB), Checksum: 086bd386cd0d91fdd39c00a2141b5e39b34bd5f4
- R_Sensus_Seattle City Light-FINAL_Redacted.pdf (40.3 MB), Checksum: 6be083b47c62037269b89eba6cb1f496c1479ac0
- S_SCL Design Summary Table-FINAL-Redacted.xlsx (22 KB), Checksum: 27e3bb409b2e35d67a24f627fcbd27f9a1eceb3e
- Sensus_Attachment 11 AMI Solution Pricing V1.1_Redacted.pdf (330 KB), Checksum: cef79d453afb04d0f7241a03d7edbcf9b69e13f3
- T_Attorney Verification Letter-FINAL.pdf (167 KB), Checksum: 9558039bf98649b6a7efb5ce458360faddc51292
Please click on the following link to download the attachments:
https://files.cairncross.com/message/EFpF1aTjDxGaa3hrGL1b1v
This email or download link can not be forwarded to anyone else.
The attachments are available until: Thursday, 30 June
Message ID: EFpF1aTj
From: Amy Akers
Good Afternoon –
Please see the link to download Exhibit B to the
Supplemental Declaration of Eric Christensen
filed today in the above referenced matter. Due to the
volume of the documents hard copies will not follow. Please let
us know if you
have any trouble with the link.
Thank you,
Amy Akers, Legal Assistant
The following files are attached to this message:
- Cover Letter_Landis+Gyr.pdf (199 KB), Checksum: a42e7d399f1fa75b58ba8ad06b708d171b5a9a19
- 1_Legal Name Verification_Website print screen.pdf (296 KB), Checksum: a5ac05bfef38347d5502d53f6f59ff3a7f61fd90
- 1_Landis+Gyr Vendor Questionnaire_REDACTED .pdf (326 KB), Checksum: ef862d6d2ca8c41cfe151880618f966c0ace1dd9
- 1A_Landis+Gyr IP Litigation Summary_December 2014.pdf (228 KB), Checksum: 1016a6ed2cfb8fab90ef308295db9f8e15c50d60
- 4_Minimum Qualifications_Landis+Gyr.pdf (412 KB), Checksum: 0cec259ed87baa49377042744140aa402f8292b2
- 5_Seller Certification.pdf (214 KB), Checksum: 0f6910d5ab4f732ed8ad1c27adf5d7ac3d2d5175
- 6_Proposed Solution.pdf (594 KB), Checksum: aa3667df5a17425e55d407170b5133d43a2c2902
- 7_Coverage and Capacity Plan.pdf (216 KB), Checksum: 227115640f68af15176f7cc52d4c8ee420d9fb9a
- 8_System Recommendations_REDACTED.pdf (452 KB), Checksum: a118a8977c83c31978ee7869da6e4f87fce6c33d
- 9_Customer References_Landis+Gyr_REDACTED.pdf (341 KB), Checksum: 1b00cfbd693b672caa76e95bc223003a1912e91d
- 10_Project Team._REDACTEDpdf.pdf (396 KB), Checksum: a6412fa345eee7a0e858de1be2f0b498bca4af5c
- 10a_L+G Management and Deployment Team Resumes_REDACTED.pdf (383 KB), Checksum: fe1dcf917c80f60126733325cd8e7304e84afdb6
- 11_Project Implementation.pdf (351 KB), Checksum: 9cef7906b732e2ab488043e4976c25351a8e341a
- 11a_Proposed Project Schedule_SCL.pdf (699 KB), Checksum: 32fa31389afdb8ee2993194bf3dd04a46db56191
- 12_Standard Hardware Warranty_REDACTED.pdf (233 KB), Checksum: 7faf32549cc15bd67b9baf32a37488a06517b284
- 13_Standard Software License and Maintenance Agreements_REDACTED.pdf (244 KB), Checksum: 988c5ae6adcca12832d5b7a36ae43f930c30d2a1
- Landis_Gyr Saas Agreement_w_ CC Schedule Attached_REDACTED.pdf (454 KB), Checksum: fb9e4fe94c06f8f2703dd737276ac0da4fd69921
- Software Support and Maintenance Agreement for Discussion_REDACTED.pdf (420 KB), Checksum: 2dbf093147018bf0451a3376c95a1e9955a8591a
- Standard Statement of Work_Seattle City Light.pdf (560 KB), Checksum: a8c41f96e4850891bd2fcd998159843caeb47998
- Item 11_Roadmap_LandisGyr_REDACTED.pdf (851 KB), Checksum: 61f35103a3a2b6224b15a46bdd500d8954972b57
- Item 13Training Recommendation Seattle City Light _REDACTED.pdf (446 KB), Checksum: e673fdd841d2a387bc9b2c0bb401671cfa1a0705
- Item 14_ Training Catalog_Redacted.pdf (939 KB), Checksum: 420fa5021443c70fc9eb3d6fc898e3dfca147d94
- Item 15_Support._REDACTED.pdf (247 KB), Checksum: 59af177b56e87139f8a4b9e051064fb658efdb90
- Acceptable Exposure Limits -Redacted.pdf (475 KB), Checksum: a832c17dfc843050f74690cc33a46f1e0c08c96a
- Req 7_Network Discovery Process-redacted.pdf (325 KB), Checksum: 7f77c40e9ac36be3268ebf331f9f34db4446c329
- Req 9_Security Overview-redacted.pdf (331 KB), Checksum: 07ccedbe87440734c212949ed36ee2d064736e5d
- Value Added 6_Daily Collection-redacted.pdf (533 KB), Checksum: dd85fab1f2b1a2e50eae40ceaafb03c9d5adda5d
- Value Added 10_Network Recovery-redacted.pdf (311 KB), Checksum: 58a57bdfd0036ecbbb82c8911b2b31b317412ac3
- Value Added 8_Events White Paper.pdf (1010 KB), Checksum: 0cfa8c22a88aefd12ed690e7bcd5403589fc9762
- Val Add 5_Gridstream DLC.pdf (1.51 MB), Checksum: 9d73e07784bfa7d8f3360c4b862fcfbfdfad3260
- Att_10 Solution Requirements_Redacted.pdf (519 KB), Checksum: 5f25dfdbbe690db5ffb2196404eb7591ab977312
- Att 11_AMI Solution Pricing V1.1-redacted.pdf (3.65 MB), Checksum: a8c458c16a6755faab695e747a17ae479e4a12b7
- Landis+Gyr Clarifications - Seattle City Light FINAL-REDACTED.pdf (360 KB), Checksum: d1f51bde8e85074181c942b813c6cb3e58790cfb
- 17_Outsourced or Managed Services Proposal_REDACTED.pdf (392 KB), Checksum: 5e0a012c887449a064ba263bbccf94fd83384c30
- 18_City Wide Wi-Fi Network.pdf (216 KB), Checksum: f36e7ebcff11da052ef8b7d4fd3414592990a2b3
- Landis+Gyr Legal Review Terms.pdf (537 KB), Checksum: a0f6bc2ed7a86c2674877c4754e2b8b364e78640
- SCL_Table of Contents_Issue_May_5_2-16.pdf (401 KB), Checksum: b925f48d3a50d412dd1568209fae497ef2dfec93
Please click on the following link to download the attachments:
https://files.cairncross.com/message/22VpTdSh2XA6H2LN9q7fpp
This email or download link can not be forwarded to anyone else.
The attachments are available until: Thursday, 30 June
Message ID: 22VpTdSh
From: Amy Akers
Good Afternoon –
Please see the link to download Exhibits C and D to the
Supplemental Declaration of Eric Christensen filed today in the
above referenced matter. Due to the
volume of the documents hard copies will not follow. Please let
us know if you
have any trouble with the link.
Thank you,
Amy Akers, Legal Assistant
The following files are attached to this message:
- January 9 Submissions.pdf (25.6 MB), Checksum: c647a52a71a49dfdc33cc2bd5ef1db847bd9ba40
- March 5 Submissions (redacted).pdf (6.22 MB), Checksum: 6d583d9a085a525e1d97c4e504d813969f8923d0
- March 12 Submissions.pdf (926 KB), Checksum: b4e27dd06a2282428cac19ac074e07807a9248b4
- Exhibit D.pdf (2.6 MB), Checksum: fb31da9df75785602332e8f760a54d4b6dac573f
Please click on the following link to download the attachments:
https://files.cairncross.com/message/LQ4HN7fTk9ntDhMKYHguJi
This email or download link can not be forwarded to anyone else.
The attachments are available until: Thursday, 30 June
Message ID: LQ4HN7fT
From: Williams, Susan E
Good morning,
Attached please find City's Response to Plaintiff's Motion for Preliminary Injunction with responsive documents that were filed in King County Superior Court this morning.
Thank you,
[image001]
Susan Williams
Paralegal
Seattle City Attorney's Office
Civil Division
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7097
Phone: 206-727-3973
FAX: 206-684-8284
susan.williams@seattle.gov<mailto:susan.williams@seattle.gov>
CONFIDENTIALITY STATEMENT: This message may contain information that is protected by the attorney-client privilege, the attorney work product doctrine, or by other confidentiality provisions. If this message was sent to you in error, any use, disclosure, or distribution of its contents is prohibited. If you receive this message in error, please contact me at the telephone number or e-mail address listed above and delete this message without printing, copying, or forwarding it. Thank you.
-
image001
From: Williams, Susan E
Good morning,
Attached please find City's Response to Plaintiff's Motion for Preliminary Injunction with responsive documents that were filed in King County Superior Court this morning.
Thank you,
[image001]
Susan Williams
Paralegal
Seattle City Attorney's Office
Civil Division
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7097
Phone: 206-727-3973
FAX: 206-684-8284
susan.williams@seattle.gov<mailto:susan.williams@seattle.gov>
CONFIDENTIALITY STATEMENT: This message may contain information that is protected by the attorney-client privilege, the attorney work product doctrine, or by other confidentiality provisions. If this message was sent to you in error, any use, disclosure, or distribution of its contents is prohibited. If you receive this message in error, please contact me at the telephone number or e-mail address listed above and delete this message without printing, copying, or forwarding it. Thank you.
-
image001
From: Alicia Cason
Good morning,
Attached please find the following:
* Ericsson's Reply in Support of Motion for Preliminary Injunction;
* Supplemental Declaration of Mark Burke.
Thank you,
Alicia
Alicia R. Cason
Stokes Lawrence, P.S.
1420 Fifth Avenue, Suite 3000 | Seattle, WA 98101-2393
Tel.: (206) 626-6000 | Fax: (206) 464-1496
Email: Alicia.Cason@stokeslaw.com<mailto:Alicia.Cason@stokeslaw.com> | Web: www.stokeslaw.com<http://www.stokeslaw.com>
Before printing this e-mail, please consider whether printing is necessary. Think Green!
This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee(s) named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.
From: Franklin, Erica R
Dear Mr. Mocek and Mr. Morisy:
Attached please find courtesy copies of the documents the City of Seattle filed in the above-referenced matter. It is our understanding that you are not represented by counsel in this particular matter; please let us know if that is not the case.
Best,
Erica
[image001]
Erica Franklin
Assistant City Attorney
Seattle City Attorney's Office
Civil Division
701 Fifth Avenue, Suite 2050
Seattle, WA 98104-7097
Phone: 206-733-9309
FAX: 206-684-8284
erica.franklin@seattle.gov<mailto:erica.franklin@seattle.gov>
CONFIDENTIALITY STATEMENT: This message may contain information that is protected by the attorney-client privilege, the attorney work product doctrine, or by other confidentiality provisions. If this message was sent to you in error, any use, disclosure, or distribution of its contents is prohibited. If you receive this message in error, please contact me at the telephone number or e-mail address listed above and delete this message without printing, copying, or forwarding it. Thank you.
-
image001
From: SCL_CityLight_PDR
Dear Mr. Mocek,
I would like to give you an update on your public records request dated April 12, 2016 as shown below. I will have the Ericsson and Elster Solutions redacted bids in the mail to you early next week.
Thank you for your patience and let me know if you have any questions.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
-
image001
From: Seattle City Light
A copy of documents responsive to the request.
There are too many files to display on this communication. See all files
From: Seattle City Light
A copy of documents responsive to the request.
There are too many files to display on this communication. See all files
From: Seattle City Light
A copy of documents responsive to the request.
There are too many files to display on this communication. See all files
From: Phil Mocek
Dear Ms. Irwin,
Please remember that I would like to receive these public records in their native electronic format. If, instead, a new record is created for me by printing the electronic records then digitizing them (i.e., "scanning" them), then the public will not be able to use computers to search and index the text within our public records (e.g., to search for keywords, to find them via Web search engines, etc.) In case you require assistance this matter, I can report that Seattle Police Department, regularly perform such redaction of electronic documents, resulting in production of the records in their native electronic format.
Please also remember to cite specific exemptions to the Public Record Act for each section of redacted material as the Public Records Act requires, and please "black out" rather than "white out" anything redacted, so that it is clear where you have withheld information from the public.
Cordially,
Phil Mocek
From: SCL_CityLight_PDR
Dear Mr. Mocek,
Attached please find a copy of the Preliminary Injunction order issued today in the matter of Ericsson v. City. As you will note, the order incorporated the redactions proposed by Ericsson. As these identical redactions are reflected in the documents I sent to you on June 3, 2016, I will not be sending an additional copy of the RFP document.
Please let me know if you have any questions.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
GENERAL MANAGER'S TEAM
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
-
image001
From: Phil Mocek
Dear Ms. Irwin,
Please note that only a tiny fraction of the information [Ericsson now claim][1] to be confidential was designated by them as confidential in the [completed vendor questionnaire][2] they submitted with their bid (page 7, "City Non
Disclosure Request").
I hope City of Seattle will take appropriate action to ensure public access to the information submitted to your agency by each of your vendors that those vendors explicitly acknowledged to be public record. To allow them to later revise their list of confidential information submitted will put to a disadvantage those bidders who carefully provided an assessment of what information in their bid was intended to be confidential, as well as those bidders who simply refrained from providing confidential information in bids they provide to public agencies.
[1]: <https://d3gn0r3afghep.cloudfront.net/foia_files/2016/06/13/Order_for_preliminary_injunction.pdf>
[2]: <https://d3gn0r3afghep.cloudfront.net/foia_files/2016/06/09/03_Ericsson_-_SCL_AMI_Solution_-_Vendor_Questionnaire_Rev_A.pdf>
Cordially,
Phil Mocek
From: Seattle City Light
A copy of documents responsive to the request.
From: SCL_CityLight_PDR
Dear Mr. Mocek,
Pursuant to your public disclosure request as shown below, and the court's order, I am sending you Elster's final redacted bid, via regular mail today.
This completes City Light's response and closes your request.
Please let me know if you have any other questions.
Sincerely,
STACY IRWIN | PUBLIC DISCLOSURE OFFICER
CUSTOMER SERVICE, COMMUNICATIONS & REGULATORY AFFAIRS
[cid:image002.png@01D052AC.192A9CE0]
Stacy.irwin @ seattle.gov
TEL (206) 684-7998
-
image001
From: Shannon Jost
Dear Mr. Mocek and Mr. Stahl:
I am including both of you on this email since although Mr. Mocek did not formally appear nor was he represented by counsel in the above-captioned matter, I understand that Mr. Stahl has represented Mr. Mocek in a separate but related matter.
In June, the Court entered a preliminary injunction order in the above-referenced case (copy attached), allowing redaction and sealing of, and prohibiting distribution of unredacted documents revealing, the trade secret, proprietary and confidential information of Ericsson and its Interested Vendors that was submitted in connection with Ericsson's smart metering bid to Seattle City Light. As you may recall, those records were the subject, inter alia, of a Washington Public Records Act request by Mr. Mocek.
Kindly advise whether Mr. Mocek would oppose a motion by Ericsson to make the preliminary injunction permanent based on the same record. Because the Court already has reviewed the affidavits and the documents and information at issue and determined that they warrant redaction/sealing, there should be no need for any further documentary evidence or testimony.
Please call me with any questions or if you would like to discuss. We request your response by no later than Tuesday, November 8, 2016. If you do not respond by that date, we will presume that Mr. Mocek does not oppose Ericsson's proposed Motion to make the preliminary injunction permanent.
Thank you,
Shannon M. Jost (v-card<http://www.stokeslaw.com/profile/attorneys/shannon-m-jost/vcard> | bio<http://www.stokeslaw.com/profile/attorneys/shannon-m-jost>)
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Stokes Lawrence, P.S. - Realizing your vision.
1420 Fifth Avenue, Suite 3000 | Seattle, WA 98101-2393
Tel.: (206) 892-2124 | Fax: (206) 464-1496
Email: shannon.jost@stokeslaw.com<mailto:shannon.jost@stokeslaw.com> | Web: www.stokeslaw.com<http://www.stokeslaw.com>
This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee(s) named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.
From: Alicia Cason
Dear Mr. Mocek,
Attached please find the following:
* Note for Motion;
* Plaintiff's Unopposed Motion for Permanent Injunction;
* Declaration of Shannon M. Jost in Support of Plaintiff's Unopposed Motion for Permanent Injunction; and
* Proposed Order Granting Plaintiff's Unopposed Motion for Permanent Injunction.
You are being provided with these documents via email because you have not supplied a valid mailing/service address.
Thank you,
Alicia
Alicia R. Cason
Stokes Lawrence, P.S.
1420 Fifth Avenue, Suite 3000 | Seattle, WA 98101-2393
Tel.: (206) 626-6000 | Fax: (206) 464-1496
Email: Alicia.Cason@stokeslaw.com | Web: www.stokeslaw.com
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This e-mail may contain confidential information which is legally privileged. The information is solely for the use of the addressee(s) named above. If you are not the intended recipient, any disclosure, copying, distribution or other use of the contents of this information is strictly prohibited. If you have received this e-mail in error, please notify us by return e-mail and delete this message. Thank you.
From: Alicia Cason
Dear Mr. Mocek,
Attached please find Plaintiffs' Reply in Support of Unopposed Motion for Permanent Injunction.
Thank you,
Alicia
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