Perfect 10 Inc v. Google Inc et al

Filing 966

STATEMENT of NOTICE SUBMITTING TO THE COURT GOOGLE'S RESPONSES AND OBJECTIONS TO PERFECT 10'S FOURTEENTH SET OF REQUESTS FOR THE PRODUCTION OF DOCUMENTS, SUBMITTED IN CONNECTION WITH PERFECT 10'S MOTION FOR REVIEW OF, AND OBJECTIONS TO, MAGISTRATE JUDGE HILLMAN'S JUNE 16, 2010 ORDER re: MOTION for Review of and Objections to, Magistrate Judge Hillman's June 16, 2010 Order On Perfect 10's Motion For Evidentiary And Other Sanctions Against Defendant Google Inc. re Minutes of In Chambers Order/Directive - no proceeding held, #923 filed by Plaintiff Perfect 10 Inc. (Attachments: #1 Declaration of Jeffrey N. Mausner In Support of Notice Submitting to the Court Google's Responses and Objections to Perfect 10's Fourteenth Set of Requests for the Production of Documents)(Mausner, Jeffrey)

Perfect 10 Inc v. Google Inc et al

Doc. 966 Att. 1

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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 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, v. Plaintiff, Case No. CV 04-9484 AHM (SHx) Before Judge A. Howard Matz DECLARATION OF JEFFREY N. MAUSNER IN SUPPORT OF NOTICE SUBMITTING TO THE COURT GOOGLE'S RESPONSES AND OBJECTIONS TO PERFECT 10'S FOURTEENTH SET OF REQUESTS FOR THE PRODUCTION OF DOCUMENTS, SUBMITTED IN CONNECTION WITH PERFECT 10'S MOTION FOR REVIEW OF, AND OBJECTIONS TO, MAGISTRATE JUDGE HILLMAN'S JUNE 16, 2010 ORDER Date: None Set Time: None Set Place: Courtroom 14, Courtroom of the Honorable A. Howard Matz Discovery Cut-Off Date: None Set Pretrial Conference Date: None Set Trial Date: None Set

GOOGLE INC., a corporation, Defendants.

Declaration of Jeffrey N. Mausner In Support of Notice Submitting To The Court Google's Responses and Objections To Perfect 10's Fourteenth Set of Requests For The Production Of Documents
Dockets.Justia.com

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DECLARATION OF JEFFREY N. MAUSNER I, Jeffrey N. Mausner, declare as follows: I am a member of the State Bar of California and admitted to practice before this Court. I am counsel of record for Plaintiff Perfect 10, Inc. ("Perfect 10") in this action. All of the matters stated herein are of my own personal knowledge, except where otherwise stated, and if called as a witness, I could and would testify competently thereto. 2. Attached hereto as Exhibit A is a true and correct copy of Defendant Google Inc.'s Responses and Objections to Plaintiff Perfect 10 Inc.'s Fourteenth Set of Requests for the Production of to Documents, which was served on August 16, 2010. 3. Attached hereto as Exhibit B is a true and correct copy of a letter that I received from Google's attorney, Brad Love, on August 16, 2010, re: Perfect 10, Inc. v. Google Inc.: stay of discovery pending appeal. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge. Executed on August 18, 2010 at Berkeley, California. __________________________________ Jeffrey N. Mausner

1 Declaration of Jeffrey N. Mausner In Support of Notice Submitting To The Court Google's Responses and Objections To Perfect 10's Fourteenth Set of Requests For The Production Of Documents

Exhibit A

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Michael T. Zeller (Bar No. 196417) 2 [e-mail] 865 South Figueroa Street, 10th Floor 3 Los Angeles, California 90017-2543 Telephone: ~13) 443-3000 4 FacsImile: 213) 443-3100 Charles K. erhoeven (BarNo. 170151) 5 [e-mail] 50 California Street, 22nd Floor 6 San Francisco 1 California 94111 Rachel HerrIck Kassabian (Bar No. 191060) 7 rachelkassabian(a),quinnemanuel.com 555 Twin DolphinlJrive, Fifth Floor 8 Redwood Shores, California 94065-2139 9 Attorneys for Defendant GOOGLE INC. 10 11 12 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CASE NO. CV 04-9484 AHM (SHx) DEFENDANT GOOGLE INC.'S RESPONSES AND OBJECTIONS TO PLAINTIFF PERFECT 10, INC.'S FOURTEENTH SET OF REQUESTS FOR THE PRODUCTION OF DOCUMENTS

PERFECT 10, INC., a California 13 corporation, 14 15 vs. Plaintiff,

16 GOOGLE INC. a corporation; and DOES 1 through 100, mclusive, 17 Defendants. 18

PLAINTIFF PERFECT 10, INC. DEFENDANT GOOGLE, INC. FOURTEEN 415-452

01980.51320/3607372.2

Case No. CV 04-9484 AHM (SHx) GOOGLE'S RESPONSES TO PERFECT 1O'S FOURTEENTH SET OF DOCUMENT REOUESTS

1

Pursuant to Rule 34 of the Federal Rules of Civil Procedure, Defendant

2 Google Inc. ("Google") hereby responds and objects to the Fourteenth Set of 3 Request