LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 143

NOTICE OF MOTION AND MOTION to Supplement Factual Record in Opposition to Defendant Rocket Lawyer Incorporated's Motion for Summary Judgment 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 Aaron Allan, # 2 Declaration of Barak Vaughn, # 3 Proposed Order)(Heather, Fred)

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PATRICIA L. GLASER - State Bar No. 55668
[e-mail]
FRED D. HEATHER - State Bar No. 110650
[e-mail]
AARON P. ALLAN - State Bar No. 144406
[e-mail]
GLASER WEIL FINK HOWARD
AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
LegalZoom.com, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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LEGALZOOM.COM, INC., a Delaware
corporation,
Plaintiff,

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v.

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ROCKET LAWYER INCORPORATED,
a Delaware corporation,

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Defendant.

CASE NO.: CV 12-9942-GAF (AGRx)
Hon. Gary A. Feess
Courtroom: 740
REDACTED DECLARATION OF
BARAK VAUGHN IN SUPPORT
OF THE MOTION OF
LEGALZOOM.COM, INC. TO
SUPPLEMENT FACTUAL
RECORD IN OPPOSITION TO
DEFENDANT ROCKET LAWYER
INCORPORATED’S MOTION FOR
SUMMARY JUDGMENT
Date:
October 27, 2014
Time:
9:30 p.m.
Courtroom: 740

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REDACTED DECLARATION OF BARAK VAUGHN IN SUPPORT OF LEGALZOOM.COM, INC.’S MOTION TO
SUPPLEMENT FACTUAL RECORD
939278

DECLARATION OF BARAK VAUGHN
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I, BARAK VAUGHN,declare as follows:

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1.

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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 to Supplement Factual Record In
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Opposition To Defendant Rocket Lawyer Incorporated's Motion For Summary
Judgment(the "Motion"). I am over the age of 18 years. Unless otherwise indicated,

s I have personal knowledge of the matters stated herein and, if called upon to do so, I
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could and would competently testify to them under oath.
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Attached hereto as Exhibit L is a true and correct copy of

3.

Attached hereto as Exhibit M is a true and correct copy of

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Attached hereto as Exhibit N is a true and correct copy of

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Attached hereto as Exhibit O is a true and correct copy of an email

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between Jen Mazzon of Rocket Lawyer and David Baga of Rocket Lawyer dated

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August 11, 2010, Bates Nos. RLI0037098-99.

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Attached hereto as Exhibit P is a true and correct copy of an email

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between Katherine K. of Google and Charley Moore of Rocket Lawyer dated

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December 2, 2011, Bates Nos. RLI0042339-40.

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Attached hereto as Exhibit Q is a true and correct copy of

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DECLARATION OF BARAK VAUGHN IN SUPPORT OF LEGALZOOM.COM, INC.'S MOTION TO
SUPPLEMENT FACTUAL RECORD
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I declare under penalty of perjury under the laws ofthe United States of

2 America and the State of California that the foregoing is true and correct.
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Executed on this 6th day of October, 2("

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939278

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VAUGHN IN SUPPORT OF LEGALZOOM.COM,INC.'S MOTION TO
DECLARATION OF BARAK
SUPPLEMENT FACTUAL RECORD

EXHIBITS L-N
ARE REDACTED IN THEIR ENTIRETY
AND FILED UNDER SEAL

EXHIBIT O

EXHIBIT P

EXHIBIT Q
IS REDACTED IN THEIR ENTIRETY
AND FILED UNDER SEAL