LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 170

REPLY IN SUPPORT OF EX PARTE APPLICATION for Leave to TO FILE MOTION TO SUPPLEMENT FACTUAL RECORD IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT AND TO SET BRIEFING SCHEDULE 166 filed by Defendant Rocket Lawyer Incorporated. (Attachments: # 1 DECLARATION OF MICHAEL T. JONES IN SUPPORT OF ROCKET LAWYER INCORPORATED'S REPLY IN SUPPORT OF ITS EX PARTE APPLICATION TO FILE MOTION TO SUPPLEMENT THE FACTUAL RECORD)(Jones, Michael)

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Forrest A. Hainline III (SBN 64166)
[e-mail]
Hong-An Vu (SBN 266268)
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111-4003
Tel.: [phone]
Fax.: [phone]
Michael T. Jones (SBN 290660)
[e-mail]
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
Tel.: [phone]
Fax.: [phone]
Brian W. Cook (Pro Hac Vice)
[e-mail]
GOODWIN PROCTER LLP
53 State Street
Boston, Massachusetts 02109-2802
Tel.: [phone]
Fax.: [phone]
Attorneys for Defendant
ROCKET LAWYER INCORPORATED

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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,
v.
ROCKET LAWYER
INCORPORATED, a Delaware
corporation,
Defendant.

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NO. 2:12-CV-09942-GAF-AGR

Case No. 2:12-cv-09942-GAF-AGR
DECLARATION OF MICHAEL T.
JONES IN SUPPORT OF ROCKET
LAWYER INCORPORATED’S
REPLY IN SUPPORT OF ITS EX
PARTE APPLICATION TO FILE
MOTION TO SUPPLEMENT THE
FACTUAL RECORD
Judge:
Courtroom:

Judge Gary A. Feess
740
255 East Temple Street
Los Angeles, CA 90012
Action Filed: November 20, 2012

DECLARATION OF MICHAEL T. JONES

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Michael T. Jones declares:

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1.

I am a partner at Goodwin Procter LLP, counsel of record for defendant

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and counterclaimant Rocket Lawyer Incorporated (“Rocket Lawyer”). I submit this

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declaration in support of Rocket Lawyer’s Reply in Support of Its Ex parte

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Application to File Motion to Supplement the Factual record. I am over the age of

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18 years. Unless otherwise indicated, I have personal knowledge of the matters

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stated herein and, if called upon to do so, I could and would competently testify to

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them under oath.

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2.

Attached hereto as Exhibit A is a true and correct copy of excerpts from

the deposition of Brian Liu, dated October 7, 2014.
3.

Attached hereto as Exhibit B are true and correct excerpts from the

deposition of Travis Giggy, dated October 9, 2014.
4.

Attached hereto as Exhibit C are true and correct excerpts from the

deposition of Dorian Quispe, dated October 7, 2914.

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I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct. Executed on this 23rd day of October, 2014.

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/s/ Michael T. Jones
MICHAEL T. JONES

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EXHIBIT A

[CONFIDENTIALLODGED UNDER SEAL]

EXHIBIT A

EXHIBIT B

[CONFIDENTIALLODGED UNDER SEAL]

EXHIBIT B

EXHIBIT C

[CONFIDENTIALLODGED UNDER SEAL]

EXHIBIT C