Perfect 10 Inc v. Google Inc et al

Filing 598

PERFECT 10'S OPPOSITION TO GOOGLE'S IMPROPER EX PARTE APPLICATION in Opposition to re: EX PARTE APPLICATION to Compel re: Perfect 10, Inc.: Defendant Google Inc.'s Joinder in Defendants Amazon.com, Inc. and Alexa Internet's Ex Parte Application for an Order Compelling Perfect 10, Inc. to Affix Production Numbers to its Product #596 filed by Plaintiff Perfect 10 Inc. (Mausner, Jeffrey)

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Jeffrey N. Mausner (State Bar No. 122385) Law Offices of Jeffrey N. Mausner Warner Center Towers 21800 Oxnard Street, Suite 910 Woodland Hills, California 91367-3640 Email: [e-mail] Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Perfect 10, Inc. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PERFECT 10, INC., a California corporation, Plaintiff, v. GOOGLE, INC., a corporation; and DOES 1 through 100, inclusive, Case No. CV 04-9484 AHM (SHx) Consolidated with Case No. CV 05-4753 AHM (SHx) PERFECT 10'S OPPOSITION TO GOOGLE'S IMPROPER EX PARTE APPLICATION Before Judge Stephen J. Hillman

Date: None Set Defendant. ______________________________ Time: None Set Place: Courtroom 14, Courtroom of the Honorable A. Howard Matz AND CONSOLIDATED CASE. Discovery Cut-Off Date: None Set Pretrial Conference Date: None Set Trial Date: None Set

Perfect 10's Opposition to Google's Improper Ex Parte Application

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Plaintiff Perfect 10, Inc. ("Perfect 10") opposes the improper ex parte application filed today, November 2, 2009, by Defendant Google, Inc. ("Google") on the grounds to be set forth tomorrow, November 3, 2009 at 10:00 A.M., during the telephonic hearing already scheduled before Judge Stephen J. Hillman. Perfect 10 also opposes Google's ex parte application, on the same grounds as set forth in its opposition to Amazon's ex parte application, which Perfect 10 filed on October 31, 2009, Case No. 05-4753, Docket No. 356. Perfect 10 does want to emphasize, once again, that Google did not: 1. 2. Follow Judge Hillman's order to Bates number the documents using the Adobe numbering system. Obtain an expert to determine the cost of Bates numbering the documents. Only Perfect 10 did that. Google criticizes the conclusion reached by Perfect 10's expert, but has not submitted anything to contradict what he says. Perfect 10 will state the remainder of its opposition to Google's ex parte application during the hearing this morning. Dated: November 3, 2009 Respectfully submitted, Law Offices of Jeffrey N. Mausner Jeffrey N. Mausner By: ________________________________ Jeffrey N. Mausner Attorney for Plaintiff Perfect 10, Inc.

Perfect 10's Opposition to Google's Improper Ex Parte Application

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