Perfect 10 Inc v. Google Inc et al

Filing 866

NOTICE OF MOTION AND MOTION for Protective Order for relief from P10's Deposition Notice Directed to Dr. Eric Schmidt filed by Defendant and Counterclaimant Google Inc. Motion set for hearing on 6/28/2010 at 02:00 PM before Magistrate Judge Stephen J. Hillman. (Attachments: #1 Proposed Order)(Kassabian, Rachel)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Michael T. Zeller (Bar No. 196417) [e-mail] 2 865 South Figueroa Street, 10th Floor 3 Los Angeles, California 90017-2543 Telephone: [phone] Facsimile: [phone] Charles K. Verhoeven (Bar No. 170151) [e-mail] 5 50 California Street, 22nd Floor 6 San Francisco, California 94111 Rachel Herrick Kassabian (Bar No. 191060) [e-mail] 7 555 Twin Dolphin Drive, 5th Floor 8 Redwood Shores, California 94065 Attorneys for Defendant GOOGLE INC. 9 10 11 12 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 21 22 23 24 25 26 27 28
01980.51320/3481432.1

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NO. CV 04-9484 AHM (SHx) DISCOVERY MATTER GOOGLE INC.'S NOTICE OF MOTION AND MOTION FOR A PROTECTIVE ORDER REGARDING P10'S DEPOSITION NOTICE DIRECTED TO DR. ERIC SCHMIDT [Joint Stipulation, Declarations of Bradley R. Love and Kris Brewer, and (Proposed) Order filed concurrently] Hon. Stephen J. Hillman Date: June 28, 2010 Time: 2:00 p.m. Crtrm.: 550 Discovery Cutoff: None Set Pretrial Conference Date: None Set Trial Date: None Set

Defendants. AND COUNTERCLAIM

Case No. CV 04-9484 AHM (SHx) NOTICE OF MOTION AND MOTION FOR A PROTECTIVE ORDER

1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE THAT on June 28, 2010, 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. 26(c) for a protective order to prevent the 7 deposition of its Chief Executive Officer, Dr. Eric Schmidt. 8 Google's motion is based on this notice of motion and motion, the Joint 9 Stipulation filed concurrently herewith, the accompanying Declarations of Bradley 10 R. Love and Kris Brewer and the Exhibits thereto, all other pleadings and papers on 11 file in this action, any matters of which this Court may take judicial notice, and such 12 further evidence and argument as may be presented at or before the hearing on this 13 matter. 14 16 2010. 17 DATED: May 4, 2010 18 19 20 21 22 23 24 25 26 27 28
01980.51320/3481432.1

Pursuant to Local Rule 37-1, the parties met and conferred on the matters in

15 this Motion telephonically on April 19, 2010, and in writing on April 9, 21 and 22, QUINN EMANUEL URQUHART & SULLIVAN, LLP

By Rachel Herrick Kassabian Attorneys for Defendant GOOGLE INC.

Case No. CV 04-9484 AHM (SHx) -1NOTICE OF MOTION AND MOTION FOR A PROTECTIVE ORDER