Perfect 10 Inc v. Google Inc et al

Filing 407

NOTICE OF MOTION AND MOTION to Compel Perfect 10, Inc. to Produce Documents, Comply with the Protective Order, and Affix Document Control Numbers to its Document Productions filed by Defendant and Counterclaimant Google Inc. Motion set for hearing on 6/1/2009 at 02:00 PM before Magistrate Judge Stephen J. Hillman. (Attachments: #1 Proposed Order Granting Google Inc.'s Motion to Compel Perfect 10 to Produce Documents, Comply with the Protective Order, and Affix Document Control Numbers to its Document Productions)(Herrick, Rachel)

Perfect 10 Inc v. Google Inc et al

Doc. 40

1 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Michael T. Zeller (Bar No. 196417) michaelzeller@quinne manuel.com 2 865 South Figueroa Street, 10th Floor 3 Los Angeles, California 90017-2543 Telephone: [phone] Facsimile: [phone] Charles K. Verhoeven (Bar No. 170151) charlesverhoeven@quinne manuel.com 5 50 California Street, 22nd Floor 6 San Francisco, California 94111 Rachel Herrick Kassabian (Bar No. 191060) rachelkassabian@quinne manuel.com 7 555 Twin Dolphin Drive, Suite 560 8 Redwood Shores, California 94065-213 9 Attorneys for Defendant Google Inc. 10 11 12 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NO. CV 04-9484 AHM (SHx) [Consolidated with Case No. CV 054753 AHM (SHx)] DISCOVERY MATTER GOOGLE INC.'S NOTICE OF MOTION AND MOTION TO COMPEL PERFECT 10 (1) TO PRODUCE DOCUMENTS, (2) TO COMPLY WITH PROTECTIVE ORDER, AND (3) TO AFFIX DOCUMENT CONTROL NUMBERS TO ITS DOCUMENT PRODUCTION [Joint Stipulation, Declaration of Rachel Herrick Kassabian, and (Proposed) Order filed concurrently herewith] Hon. Stephen J. Hillman Date: June 1, 2009 Time: 2:00 PM Crtrm.: 550 Discovery Cutoff: None Set Pretrial Conference Date: None Set Trial Date: None Set

13 PERFECT 10, INC., a California corporation, 14 Plaintiff, 15 vs. 16 GOOGLE INC., a corporation; and 17 DOES 1 through 100, inclusive, 18 19 20 22 23 vs. Defendants. AND COUNTERCLAIM

PERFECT 10, INC., a California 21 corporation, Plaintiff,

24 AMAZON.COM, INC., a corporation; A9.COM, INC., a corporation; and 25 DOES 1 through 100, inclusive, 26 27 28 Defendants.

Case No. CV 04-9484 AHM (SHx) [Consolidated with Case No. CV 05-4753 AHM (SHx)] GOOGLE INC.'S NOTICE OF MOTION AND MOTION TO COMPEL

Dockets.Justia.com

1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE THAT on June 1, 2009, at 2:00 p.m., or as soon 3 thereafter as the matter may be heard, in the courtroom of the Honorable Stephen J. 4 Hillman, located at 255 East Temple Street, Los Angeles, CA 90012, Courtroom 5 550, defendant and counterclaim plaintiff Google Inc. ("Google") will and hereby 6 does move under Fed. R. Civ. P. 37(a)(3)(B) to compel Plaintiff Perfect 10, Inc.'s 7 ("Perfect 10") (1) to produce documents, (2) to comply with the protective order, 8 and (3) to affix document control numbers to its document production. 9 Google's motion is based on this notice of motion and motion, the Joint 10 Stipulation filed concurrently herewith, the accompanying Declarations of Rachel 11 Herrick Kassabian and the Exhibits thereto, all other pleadings and papers on file in 12 this action, any matters of which this Court may take judicial notice, and such 13 further evidence and argument as may be presented at or before the hearing on this 14 matter. 15 Pursuant to Local Rule 37-1, the parties met and conferred on the matters in 16 this Motion telephonically on February 22, 2008, October 15, 2008, and various 17 times thereafter, and in writing on July 5, 2005, January 29, 2008, March 31, 2008, 18 and various times thereafter. 19 20 DATED: May 6, 2008 21 22 23 24 25 26 27 28
Case No. CV 04-9484 AHM (SHx) [Consolidated with Case No. CV 05-4753 AHM (SHx)] GOOGLE INC.'S NOTICE OF MOTION AND MOTION TO COMPEL

QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP By /s/ Rachel Herrick Kassabian Rachel Herrick Kassabian Attorneys for Defendant Google Inc.

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