LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 127

NOTICE OF MOTION AND MOTION for Sanctions Under Rule 11; Memorandum of Points and Authorities with Redactions filed by Plaintiff LegalZoom.com Inc. Motion set for hearing on 10/27/2014 at 09:30 AM before Judge Gary A. Feess. (Attachments: # 1 Declaration of Vaughn, # 2 Declaration of Allan, # 3 Proposed Order)(Heather, Fred)

i PATRICIA L. GLASER -State Bar No. 55668
pglaser glaserweil.com
FRED .HEATHER -State Bar No. 110650
a
(heather~a,glaserweil.com
3 AARON-P. ALLAN -State Bar No. 144406
aallan glaserweil.com
GLAS R WEIL FINK HOWARD
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AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
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Los Angeles, California 90067
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Facsimile: 0310 556-2920
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Attorneys for Plaintiff
LegalZoom.com, Inc.
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CENTRAL DISTRICT OF CALIFORNIA

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UNITED STATES DISTRICT COURT

WESTERN DIVISION

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LEGALZOOM.COM,INC., a Delaware
corporation,

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Plaintiff,

CASE NO.: CV 12-9942-GAF(AGI~)
Hon. Gary A. Feess
Courtroom: 740

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ROCKET LAWYER INCORPORATED,
a Delaware corporation,

DECLARATION OF BARAK
VAUGHN IN SUPPORT OF
LEGALZOOM'S MOTION FOR
RULE 11 SANCTIONS WITH
REDACTIONS

Defendant.
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October 27, 2014
Date:
9:30 a.m.
Time:
Courtroom: 740

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Complaint Filed: November 20, 2012

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DECLARATION OF BARAK VAUGHN IN SUPPORT OF LEGALZOOM'S MOTION FOR RULE 11 SANCTIONS
926321

DECLARATION OF BARAK VAUGHN

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I, BARAK VAUGHN,declare as follows:

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I am Of Counsel at Glaser Weil Fink Howard Avchen &Shapiro,

counsel of record for Plaintiff LegalZoom.com, Inc.("LegalZoom"). I submit this

s declaration in support of LegalZoom's Motion for Rule 11 Sanctions (the "Motion").
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I am over the age of 18 years. Unless otherwise indicated, I have personal knowledge
ofthe matters stated herein and, if called upon to do so, I could and would

s competently testify to them under oath.
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DECLARATION OF BARAK VAUGHN IN SUPPORT OF LEGALZOOM'S MOTION FOR RULE ]1 SANCTIONS
926321

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I declare under penalty of perjury under the laws of the United States of

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America and the State of California that the foregoing is true and correct.

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Executed on this 26th day of September,20~

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DECLARATION OF BARAK VAUGHN IN SUPPORT OF LEGALZOOM'S MOTION FOR RULE 11 SANCTIONS
926321

EXHIBITS 1 -3
IN SUPPORT OF THE
DECLARATION OF BARAK VAUGHN
HAVE BEEN REDACTED
IN THEIR ENTIRETY