Perfect 10 Inc v. Google Inc et al

Filing 904

NOTICE OF MOTION AND MOTION to Quash Subpoena served by Perfect 10, Inc. on Ms. Shantal Rands Poovala and for a Protective Order filed by Defendant and Counter-Claimant Google Inc. Motion set for hearing on 8/16/2010 at 02:00 PM before Magistrate Judge Stephen J. Hillman. (Attachments: #1 Proposed Order)(Zeller, Michael)

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
01980.51320/3548207.1

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 TO QUASH THE POOVALA SUBPOENAS AND FOR A PROTECTIVE ORDER [Joint Stipulation, Declaration of Andrea Pallios Roberts, and (Proposed) Order filed concurrently] Hon. Stephen J. Hillman Date: August 16, 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 TO QUASH AND FOR A PROTECTIVE ORDER

1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE THAT on August 16, 2010, at 2:00 p.m., or as 3 soon thereafter as the matter may be heard, in the courtroom of the Honorable 4 Stephen J. Hillman, located at 255 East Temple Street, Los Angeles, CA 90012, 5 Courtroom 550, defendant and counterclaim plaintiff Google Inc. ("Google") will 6 and hereby does move under Fed. R. Civ. P. 26(c) and Fed. R. Civ. P. 45 to quash 7 the April 16, 2010 subpoenas served by Perfect 10, Inc. ("Perfect 10") on Ms. 8 Shantal Rands Poovala and for a protective order against their enforcement. 9 Google's motion is based on this notice of motion and motion, the Joint 10 Stipulation filed concurrently herewith, the accompanying Declaration of Andrea 11 Pallios Roberts and the Exhibits thereto, all other pleadings and papers on file in this 12 action, any matters of which this Court may take judicial notice, and such further 13 evidence and argument as may be presented at or before the hearing on this matter. 14 Pursuant to Local Rule 37-1, the parties met and conferred on the matters in 15 this Motion telephonically on June 9, 2010, and in writing on April 23, June 6, June 16 8, June 9, June 11, and June 12, 2010. 17 18 DATED: June 23, 2010 19 20 21 22 23 24 25 26 27 28
01980.51320/3548207.1

QUINN EMANUEL URQUHART & SULLIVAN, LLP

By Michael T. Zeller Attorneys for Defendant GOOGLE INC.

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