Countering the RIAA's post-argument submission to Magistrate Judge Levy, in support of its protective order motion to conceal the MediaSentry contracts from Ms. Lindor's attorneys, in UMG v. Lindor, Ms. Lindor submitted the expert witness declaration and court's decision in Foundation v. UPC Nederland, which detailed a number of ways in which the investigations of plaintiffs' witness -- Tom Mizzone of MediaSentry -- were inherently unreliable. Ms. Lindor's attorneys said that this heightened the need for a thorough deposition and crossexamination of Mr. Mizzone, since the RIAA's attorneys had revealed at the oral argument that Mr. Mizzone was the sole MediaSentry witness they were intending to call.
December 15, 2006, Letter of Ray Beckerman to Magistrate Robert M. Levy*
Expert Witness Declaration in Foundation v. UPC Nederland*
Court Decision in Foundation v. UPC Nederland*
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