LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 179

JOINT Exhibit List filed by defendant/counterclaimant Rocket Lawyer Incorporated.. (Jones, Michael)

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1 2 3 4 Forrest A. Hainline III (SBN 64166) fhainline@goodwinprocter.com GOODWIN PROCTER LLP Three Embarcadero Center, 24th Floor San Francisco, California 94111 Tel.: 415.733.6000 Fax.: 415.677.9041 8 Michael T. Jones (SBN 290660) mjones@goodwinprocter.com GOODWIN PROCTER LLP 135 Commonwealth Drive Menlo Park, California 94025-1105 Tel.: 650.752.3100 Fax.: 650.853.1038 9 [Addt’l counsel listed in signature block] 5 6 7 10 11 Attorneys for Defendant ROCKET LAWYER INCORPORATED 17 Patricia L. Glaser (SBN 55668) pglaser@glaserweil.com Fred D. Heather (SBN 110650) fheather@glaserweil.com Aaron P. Allan (SBN 144406) aallan@glaserweil.com GLASER WEIL FINK HOWARD AVCHEN & SHAPIRO LLP 10250 Constellation Blvd., 19th Floor Los Angeles, California 90067 Telephone: (310) 553-3000 Facsimile: (310) 556-2920 18 Attorneys for Plaintiff LEGALZOOM.COM, INC. 12 13 14 15 16 19 UNITED STATES DISTRICT COURT 20 CENTRAL DISTRICT OF CALIFORNIA 21 22 23 24 25 26 27 WESTERN DIVISION LEGALZOOM.COM, INC., a Delaware Case No. 2:12-cv-09942-GAF-AGR corporation, JOINT EXHIBIT LIST Plaintiff, PTC: November 10, 2014 v. 1:30 p.m. Trial: December 9, 2014 ROCKET LAWYER Judge: Judge Gary A. Feess INCORPORATED, a Delaware Courtroom: 740 corporation, 255 East Temple Street Los Angeles, CA 90012 Defendant. Action Filed: November 20, 2012 28 ACTIVE/79940777.1 1 Plaintiff and counterclaim defendant, LegalZoom.com, Inc., and defendant 2 and counterclaimant, Rocket Lawyer Incorporated, hereby submit the joint exhibit 3 list with each parties’ respective objections to proposed exhibits, attached hereto as 4 Exhibit A. Exhibits highlighted in yellow are exhibits offered by both parties. 5 Respectfully submitted, 6 7 DATED: October 28, 2014 8 By: /s/ Michael T. Jones FORREST A. HAINLINE III MICHAEL T. JONES HONG-AN VU BRIAN COOK Attorneys for Defendant and Counter-Claimant ROCKET LAWYER INCORPORATED 9 10 11 12 13 14 15 16 17 GOODWIN PROCTER LLP DATED: October 28, 2014 GLASER WEIL FINK HOWARD AVCHEN & SHAPIRO LLP By: /s/ Fred D. Heather PATRICIA GLASER FRED HEATHER AARON ALLAN Attorneys for Plaintiff LEGALZOOM.COM, INC. 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A No. of Exhibit Offering Party/Parties 1 Defendant Beg. Bates End Bates Date Description GIG02399 GIG02405 1/28/2009 Email from Travis Giggy to tgiggy@gmail.com re: FW: Research Brief: Pre-Shop Customer Reviews Important to Online Customers Appendix of Exhibits in Support of Motion for Partial Summary Judgment Brought by Plaintiff LegalZoom.com, Inc. Email from Scott MacDonell to Brian Liu, cc. Carrie Yutzy re: Yelp! I need somebody *****HIGHLY CONFIDENTIAL***** Email from Scott MacDonell to Travis Giggy re: disclaimer Non Offering Party's Objections Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: Relevance; Compound; Foundation No Objection 2 NA NA 7/14/2014 3 Defendant LZ001546 LZ001548 10/6/2011 4 Defendant LZ001345 LZ001346 4/4/2012 5 Defendant LZ000927 LZ000929 7/26/2011 6 Defendant LZ001087 LZ001090 7 Defendant LZ000958 LZ000958 8 Defendant LZ001733 LZ001733 9 Defendant LZ001791 LZ001792 10 Defendant LZ001238 LZ001240 11 Defendant LZ007351 LZ007354 12 Defendant GIG02188 GIG02189 13 Defendant NA NA 14 Defendant LZ001688 LZ001690 15 Defendant LZ001296 LZ001299 16 Defendant LZ007655 LZ006756 17 Defendant NA NA Defendant LZ001622 LZ001634 Date Admitted 11/30/2011 Email from Brandon Molina to Travis Giggy re: Fw: Google Policy Complaints (update) 10/7/2011 Email from Scott MacDonell to Travis Giggy re: legalspring reviews.xlsx Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 2/14/2012 Email from Scott MacDonell to Dorian Quispe re: FW: Review has been Objection: E-mails Authored entered on LegalSpring.com by Travis Giggy Are Hearsay; Foundation 2/15/2012 Email from Scott MacDonell to Brian Liu and Frank Monestere, cc. No Objection Jennifer Loo and John Suh, bcc. Jsuhbiz@gmail.com re: Not glowing reviews on LegalSpring…. Objection: E-mails Authored 2/22/2012 Email from Scott MacDonell to Travis Giggy, Carrie Yutzy, Peter by Travis Giggy Are Hearsay; Prucnel, cc. Dorian Quispe re: Review has been entered on Foundation LegalSpring.com 12/6/2011 Email from Brian Liu to Brandon Molina, John Suh, Eddie Hartman, and Objection: Relevance Scott MacDonell, cc. Dorian Quispe, Serge Topjian, Sarah Ryan, and Travis Giggy, bcc. Jsuhbiz@gmail.com re: LWL Live 7/17/2012 Email from LegalZoom to Travis Giggy re: Start a Business from Objection: Relevance Anywhere 9/22/2013 Google search results for "legalzoom 99 incorporation" Objection: Hearsay; Foundation; Relevance 12/1/2011 Email from Patty Chikamagalur to Michael Kim re: FW: Social Media - Objection: Hearsay; Foundation; Relevance November Monthly Summary 3/7/2012 Email from Patty Chikamagalur to Travis Giggy, cc. Carrie Yutzy, Peter Objection: E-mails Authored by Travis Giggy Are Hearsay; Prucnel, and Jeremy Vernassal re: Review has been entered on Foundation; Relevance LegalSpring.com 10/9/2008 Email from Jeremy Hermanns to Michael Turner, Brian Liu, Brian Lee, Objection: Hearsay; Eddie Hartman, Frank Monestere, John Suh, cc: Scott MacDonell re: Foundation; Relevance RocketLawyer.com - Free living and Last Wills 9/29/2014 LegalZoom.com, Inc.'s Second Amended Response to Defendant Rocket Objection: Relevance; Lawyer Incorporated's Notice of F.R.C.P. 30(b)(6) Deposition Foundation 18 963958.1 Defendant Date Identified Email from Scott Macdonell to Travis Giggy, cc. Brandon Molina re: Legalspring reviews 11/16/2011 Email from Legalzoom.com, Inc. to Fred Krupica re: Completed: Contract Approval Sheet & Affiliate Agreement - LegalSpring Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation No Objection Objection: Relevance 1 of 25 EXHIBIT A -2- No. of Exhibit Offering Party/Parties 19 Defendant Beg. Bates End Bates Date LZ007437 LZ007438 5/9/2006 Description Email from Brian Liu to Travis Giggy re: legalspring 20 Defendant LZ007432 LZ007436 11/15/2006 Email from Brian Liu to Brian Lee, John Suh, and Eddie Hartman, re: LegalSpring 21 Defendant LZ000976 LZ000978 10/11/2011 Email from Travis Giggy to Brandon Molina re: LegalSpring reviews 22 Defendant LZ001984 LZ001985 3/20/2012 23 Defendant LZ002228 LZ002234 24 Defendant LZ001676 LZ001677 25 Defendant LZ001684 LZ001685 12/1/2011 Email from Dorian Quispe to Matt Withers re: Legal Spring Matrix wireframe 26 Defendant LZ007420 LZ007424 2/24/2012 27 Defendant LZ007447 LZ007447 4/5/2006 Email from Dorian Quispe to Carter Gaffney, John Suh, and Brian Liu, cc. Scott MacDonell, Bo Kjaer, and Serge Topjian, bcc. Jsuhbiz@gmail.com re: LZ & RL: Site Also Visited Stats Email from Brian Liu to Travis Giggy re: More bad reviews on LS.com 28 Defendant LZ000753 LZ000755 5/26/2010 Email from Brian Liu to Travis Giggy re: LegalSpring 29 30 Defendant Defendant LZ002656_0002 LZ002656_0001 LZ002656_0002 LZ002656_0001 31 Defendant NA NA 3/11/2013 LegalZoom.com, Inc.'s Financial Performance by Quarter LegalZoom.com, Inc.'s Revenue for Advertising Incorporation Services Broken Down Quarterly Rocket Lawyer Incorporated's First Set of Requests for Production 32 Defendant NA NA 8/22/2013 Rocket Lawyer Incorporated's Second Set of Requests for Production 33 Defendant NA NA 7/1/2014 Rocket Lawyer Incorporated's Third Set of Requests for Production 34 Defendant RLI0063423 RLI0063425 6/23/2004 35 Defendant RLI0063525 RLI0063526 1/28/2009 RLI Giggy Deposition Exhibit 1 - Legalspring.com - How the Legal Industry is Being Transformed by the Internet RLI Giggy Deposition Exhibit 4 - LegalSpring reviews. The 1/28/2009 review was attached as Exhibit 9 to the July 28, 2014 Declaration of Hong-An Vu in Opposition to LegalZoom.com, Inc.'s Motion for Partial Summary Judgment Email from Serge Topjian to Dorian Quispe, cc: Brian Liu re: LegalSpring 10/27/2011 Email from Matt Scanlan to Dorian Quispe, cc: Matt Taylor and Serge Topjian re: Spanish Account Shell 12/1/2011 Email from Dorian Quispe to Matt Withers re: FW: Legal Spring Matrix wireframe via myBals NA NA 2/5/2009 36 963958.1 Defendant LZ000961 LZ000962 2/13/09 10/10/2011 RLI Giggy Deposition Exhibit 7 - Email from Travis Giggy to Scott Macdonell re: legalspring reviews.xlsx Non Offering Party's Objections Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: Relevance Date Identified Date Admitted Objection: Hearsay; Foundation; Relevance Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation No Objection Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: Relevance Objection: Relevance Objection: Relevance; Foundation Objection: Relevance; Foundation Objection: Relevance; Foundation Objection: Hearsay; Foundation Objection: Hearsay; Foundation Objection: E-mails Authored By Travis Giggy Are Hearsay; Foundation 2 of 25 EXHIBIT A -3- No. of Exhibit Offering Party/Parties 37 Defendant Beg. Bates End Bates Date LZ000915 LZ000918 5/26/2011 38 LZ001538 LZ001539 5/25/2011 39 Defendant GIG02364 GIG02365 1/6/2009 40 Defendant GIG02196 GIG02196 7/25/2012 41 Defendant GIG02291 GIG02292 12/4/2012 42 Defendant LZ007777 LZ007777 6/19/2008 43 Defendant LZ007832 LZ007833 2/18/2009 44 45 Defendant Defendant LZ002964 LZ003595 LZ002964 LZ003596 4/9/2010 6/9/2010 46 Defendant LZ003669 LZ003672 8/3/2010 47 Defendant LZ001485 LZ001487 8/27/2010 48 49 Defendant Defendant LZ003551 LZ007505 LZ003553 LZ007508 NA NA 50 Defendant LZ007539 LZ007542 7/23/2011 51 Defendant LZ003157 LZ003159 7/26/2011 52 Defendant LZ007545 LZ007546 NA 53 Defendant LZ007547 LZ007549 8/10/2011 54 55 963958.1 Defendant Defendant Defendant LZ007405 LZ007550 LZ007405 LZ007552 8/11/2011 8/13/2011 Description Non Offering Party's Date Identified Objections RLI Giggy Deposition Exhibit 10 - Email from Matt Withers to Travis Objection: E-mails Authored Giggy and Eddie Hartman re: Rocket Lawyer By Travis Giggy Are Hearsay; Foundation RLI Giggy Deposition Exhibit 11 - Email from Matt Withers to Travis Objection: E-mails Authored Giggy re: Rocket Lawyer by Travis Giggy Are Hearsay; Foundation RLI Giggy Deposition Exhibit 14 - Email from Sandra Tanzberger to Objection: E-mails Authored Travis Giggy re: LegalZoom Review Verification By Travis Giggy Are Hearsay; Foundation RLI Giggy Deposition Exhibit 15 - Email from Travis Giggy to Dorian Objection: E-mails Authored Quispe re: legalspring by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored RLI Giggy Deposition Exhibit 16 - Email from Travis Giggy to Doug Ansell re: partner by Travis Giggy Are Hearsay; Foundation Email from Travis Giggy to Eddie Hartman re: Morning Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Email from Scott MacDonell to John Suh, cc. Michael Turner, Brian Liu, Objection: Relevance Frank Monestere, Fred Krupica, and Tracy Terrill re: Updated Aided & Unaided Awareness Email from Eddie Hartman to Carter Gaffney re: Home Page Test Objection: Relevance Email from Eddie Hartman to Brian Liu, cc. James Peters re: Forms Objection: Relevance subscription Email from Adam Thomas to Frank Monestere re: FW: Inventor's Month Objection: Relevance Announcement -- DRAFT UPDATE Email from Derek Chew to Chris Cannon and Jeremy Hermanns re: No Objection customer review sites Redacted email with excerpt of a customer's complaint Objection: Hearsay; Document providing examples of competitors who are successfully bidding on "free" KWs Foundation; Relevance Email from Travis Giggy to Dorian Quispe re: Free Negative Term Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation; Relevance Email from Patty Chikamagalur to Victoria Coe, cc. Wagner Barrios, Objection: Hearsay; Monica Fletcher, Richard Appert, Yoon Choi, Aaron Hong, Peter Foundation; Relevance Prucnel, and Brian Alejandro re: BBB Complaint - Express Gold Incorporation - UT (500598061) Screenshots of Legal CenterPro's Free Trial Application, Free Trial Sign- Objection: Relevance up, and Unlimited Access Application web pages. Email from Dorian Quispe to Eddie Hartman, Scott MacDonell, and Objection: Relevance Brandon Molina, cc. Serge Topjian, Daniel Alfi, and Travis Giggy re: Gmail Targeting Email from Carter Gaffney to Eddie Hartman re: RL raises $18.5 M Objection: Relevance Email from Brandon Molina to Eddie Hartman, cc. Travis Giggy re: FW: Objection: E-mails Authored How to Quantify who is "winning" - The AdWords Game by Travis Giggy Are Hearsay; Foundation; Relevance Date Admitted 3 of 25 EXHIBIT A -4- No. of Exhibit Offering Party/Parties 56 Defendant Beg. Bates End Bates Date LZ000932 LZ000932 9/1/2011 Description Non Offering Party's Date Identified Objections Email from Travis Giggy to Scott MacDonell and Amir Pirnia re: Objection: E-mails Authored Legalzoom search on google by Travis Giggy Are Hearsay; Foundation; Relevance Email from Scott Macdonell to Travis Giggy, cc. Brandon Molina re: Objection: E-mails Authored Legalspring reviews by Travis Giggy Are Hearsay; Foundation Email from Peter Prucnel to Scott MacDonell re: legalspring reviews.xlsx Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Email from Brandon Molina to Travis Giggy re: legalspring No Objection Email from Scott MacDonell to Travis Giggy re: legalspring reviews.xlsx Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Email from Travis Giggy to Patty Chikamagalur, Carrie Yutzy, and Peter No Objection Prucnel re: Legal Spring Email from Scott MacDonell to Brandon Molina and Dorian Quispe re: No Objection LegalSpring reviews Email from Brandon Molina to Justina Altiere re: project update Objection: Relevance Email from Matt Withers to Travis Giggy re: Links No Objection Email from Travis Giggy to Scott MacDonell and Carrie Yutzy, cc. Objection: E-mails Authored Brandon Molina re: Review has been entered on LegalSpring.com by Travis Giggy Are Hearsay; Foundation Email from Peter Prucnel to Carrie Yutzy re: Review has been entered on Objection: E-mails Authored Legalspring.com by Travis Giggy Are Hearsay; Foundation Email from Charley Moore to Brian Liu re: Google Ads Objection: Hearsay; Revelance 57 LZ000944 LZ000946 9/17/2011 58 Defendant LZ001555 LZ001556 10/11/2011 59 60 Defendant Defendant LZ000969 LZ000971 LZ000969 LZ000973 10/11/2011 10/11/2011 61 Defendant LZ000992 LZ000994 10/11/2011 62 Defendant LZ001563 LZ001564 10/11/2011 63 64 65 Defendant Defendant Defendant LZ001571 LZ000999 LZ001018 LZ001572 LZ000999 LZ001020 10/17/2011 10/21/2011 10/27/2011 66 Defendant LZ001605 LZ001607 11/2/2011 67 Defendant LZ006662 LZ006663 11/16/2011 68 Defendant LZ001131 LZ001134 69 Defendant LZ001179 LZ001179 12/15/2011 Email from Scott MacDonell to Travis Giggy, cc. Carrie Yutzy, Brandon Molina, Peter Prucnel, Patty Chikamagalur, Jeremy Vernassal re: LS review 1/30/2012 Email from Travis Giggy to Peter Prucnel, cc. Scott MacDonell and Carter Gaffney re: Fwd: I have a question about Legal Spring 70 Defendant LZ001712 LZ001714 2/1/2012 71 Defendant LZ001197 LZ001197 2/1/2012 72 Defendant LZ001199 LZ001202 2/14/2012 73 Defendant LZ001759 LZ001762 2/14/2012 74 Defendant LZ001763 LZ001766 2/14/2012 75 963958.1 Defendant Defendant LZ001206 LZ001209 2/15/2012 Date Admitted Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation; Relevance Email from Dorian Quispe to Brian Liu, cc. John Suh and Serge Topjian, Objection: Relevance; More bcc. Jsuhbiz@gmail.com re: Rocketlawyer Prejudicial Than Probative Email from Scott MacDonell to Travis Giggy and Dorian Quispe re: Objection: E-mails Authored Review has been entered on LegalSpring.com by Travis Giggy Are Hearsay; Foundation; Relevance Email from Carrie Yutzy to Travis Giggy re: FW: can we get an official No Objection answer to the first two reviews here? Email from Dorian Quispe to Scott MacDonell, Carrie Yutzy, and Peter No Objection Prucnel re: can we get an official answer to the first two reviews here? Email from Carrie Yutzy to Scott MacDonell and Peter Prucnel, cc Dorian Quispe re: can we get an official answer to the first two reviews here? Email from Travis Giggy to Carrie Yutzy re: can we get an official answer to the first two reviews here? No Objection Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 4 of 25 EXHIBIT A -5- No. of Exhibit Offering Party/Parties 76 Defendant Beg. Bates End Bates Date LZ001214 LZ001217 2/16/2012 Email from Travis Giggy to Carrie Yutzy re: can we get an official answer to the first two reviews here? Email from Scott MacDonell to Brian Liu, cc. Dorian Quispe re: can we get an official answer to the first two reviews here? Email from Peter Prucnel to Carrie Yutzy and Peter Chikamagalur, cc. Scott MacDonell re: LegalSpring Email from Travis Giggy to Scott MacDonell, Carrie Yutzy, and Peter Prucnel, cc. Dorian Quispe re: Review has been entered on LegalSpring.com Email from Travis Giggy to Carrie Yutzy re: Another LegalSpring review 77 LZ001810 LZ001815 2/15/2012 78 Defendant LZ001858 LZ001863 2/16/2012 79 Defendant LZ001241 LZ001244 2/22/2012 80 Defendant LZ001245 LZ001251 2/22/2012 81 Defendant LZ001880 LZ001880 2/23/2012 82 Defendant LZ007420 LZ007424 2/24/2012 83 Defendant LZ001272 LZ001273 3/1/2012 84 Defendant LZ001988 LZ001993 3/22/2012 85 Defendant LZ002001 LZ002002 3/23/2012 86 Defendant LZ002003 LZ002004 3/28/2012 87 Defendant LZ002055 LZ002057 88 Defendant LZ002062 LZ002065 89 Defendant LZ002159 LZ002159 90 Defendant LZ002166 LZ002169 91 Defendant LZ002171 LZ002172 92 Defendant LZ001549 LZ001550 93 Defendant RLI0063406 RLI0063410 94 963958.1 Defendant Defendant RLI0063426 RLI0063427 Description Email from Scott MacDonell to Brian Liu, cc. Scott MacDonell re: legalspring Email from Dorian Quispe to Carter Gaffney, John Suh, and Brian Liu, cc. Scott MacDonell, Bo Kjaer, and Serge Topjian, bcc. Jsuhbiz@gmail.com re: LZ & RL: Site Also Visited Stats Email from Patty Chikamagalur to Travis Giggy, cc. Carrie Yutzy, Scott MacDonell, and Jeremy Vernassal re: FW: Review has been entered on LegalSpring.com Email from Jeremy Scarbury to Brandon Molina and Michelle Fortich, cc. Shilpa Joshi, Ed Baldoz, Bo Kjaer, Keith Eich, Justina Altiere, and Carter Gaffney re: Potential R&D Project Impairments Email from Dorian Quispe to Matt Withers re: LegalZoom Affiliate Relationship Email from Patty Chikamagalur to Carrie Yutzy, cc. Jeremy Vernassal and Peter Prucnel re: FW: Review has been entered on LegalSpring.com Non Offering Party's Objections Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation No Objection Date Identified Date Admitted No Objection Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation No Objection Objection: Relevance Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: Relevance Objection: Relevance Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 3/30/2012 Email from David Jin to Aaron Hong, cc Lee Gamel re: FW: LegalSpring No Objection Review - Economy Incorporation - DE (9602212) 3/31/2012 Email from Victoria Coe to Patty Chikamagalur, cc. Wagner Barrios, Objection: Relevance Mary Stanislao, and Peter Prucnel re: LegalSpring Review - Economy Incorporation - DE (9602212) 7/25/2012 Email from Pravin Chandrasoma to Tracy Terrill and Chas Rampenthal Objection: E-mails Authored re: FW: legalspring by Travis Giggy Are Hearsay; Foundation 7/25/2012 Email from Scott MacDonell to Dorian Quispe re: legalspring Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 9/20/2012 Email from Carrie Yutzy to Patty Chiamagalur re: Older LegalSpring No Objection Review 10/7/2011 Email from Scott MacDonell to Brian Liu re: FW: legalspring No Objection reviews.xlsx 12/11/2012 Print-outs from LegalSpring's website regarding The Company Objection: Hearsay; Corporation Reviews and Company Information Foundation; Relevance 1/27/2014 Print-outs from Offers.com's website regarding LegalZoom LLCs Objection: Hearsay; Foundation; Relevance 5 of 25 EXHIBIT A -6- No. of Exhibit Offering Party/Parties 95 Defendant Beg. Bates End Bates RLI0063428 RLI0063429 96 RLI0063436 RLI0063443 97 Defendant RLI0063449 RLI0063452 98 Defendant RLI0063487 RLI0063501 99 Defendant RLI0063502 RLI0063508 100 Defendant NA NA 101 Defendant NA NA 102 Defendant NA NA 103 Defendant NA NA 104 Defendant NA NA 105 Defendant GIG02135 GIG02135 106 Defendant GIG02151 GIG02151 107 Defendant GIG02287 GIG02288 108 Defendant GIG02438 GIG02443 109 Defendant GIG01249 GIG01249 110 Defendant GIG01262 GIG01263 111 Defendant GIG01825 GIG01826 112 Defendant GIG01846 GIG01848 113 Defendant GIG01869 GIG01869 114 963958.1 Defendant Defendant GIG01933 GIG01933 Date Description Non Offering Party's Objections 1/27/2014 Print-outs from pocketdeal.com's website regarding "LegalZoom coupon Objection: Hearsay; codes, LegalZoom promotions and discounts" Foundation; Relevance 7/9/2014 Print-outs from LegalSpring's website regarding BizFilings Reviews and Objection: Hearsay; Company Information Foundation; Relevance 7/9/2014 Print-outs from LegalSpring's website regarding Legalfilings.com Objection: Hearsay; Reviews and Company Information Foundation; Relevance 7/9/2014 Print-outs from LegalSpring's website regarding MyCorporation.com Objection: Hearsay; Reviews and Company Information Foundation; Relevance 7/9/2014 Print-outs from LegalSpring's website regarding The Company Objection: Hearsay; Corporation Reviews and Company Information Foundation; Relevance 12/3/2013 LegalZoom.com, Inc.'s Supplemental Responses to Rocket Lawyer No Objection Incorporated's First Set of Special Interrogatories 7/14/2014 Declaration of Travis Giggy in Support of Motion for Partial Summary No Objection Judgment Brought by Plaintiff LegalZoom.com, Inc. 7/14/2014 Declaration of Dorian Quispe in Support of Motion for Partial Summary No Objection Judgment Brought by Plaintiff LegalZoom.com, Inc. 8/28/2013 Google search results for "incorporation" Objection: Hearsay; Foundation; Relevance 9/23/2013 Legalzoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First No Objection Set of Special Interrogatories 3/8/2012 Email from Travis Giggy to himself re: Review has been entered on Objection: E-mails Authored LegalSpring.com by Travis Giggy Are Hearsay; Foundation; Relevance 3/21/2012 Email from Travis Giggy to himself re: Review has been entered on Objection: E-mails Authored LegalSpring.com by Travis Giggy Are Hearsay; Foundation; Relevance 12/4/2012 Email from Travis Giggy to Doug Ansell re: partner Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 2/11/2009 Email from Travis Giggy to Jonathan Mizel, cc. Dr. Glenn Livingston re: Objection: E-mails Authored Hi Jonathan :-) by Travis Giggy Are Hearsay; Foundation 11/2/2009 Email from Matt Withers to Travis Giggy re: LegalZoom Order Objection: Relevance Notification 1/4/2010 Email from Travis Giggy to Monique (winebrat@gmail.com) re: Startup Objection: E-mails Authored Victory - 7 Steps to Startup S.U.C.C.E.S.S. by Travis Giggy Are Hearsay; Foundation; Relevance 10/11/2011 Email from Travis Giggy to Debra Toner re: Debra, download your free Objection: E-mails Authored LLC guide now by Travis Giggy Are Hearsay; Foundation; Relevance 10/14/2011 Email from Travis Giggy to Debra Toner re: Debra, download your free Objection: E-mails Authored LLC guide now by Travis Giggy Are Hearsay; Foundation; Relevance 11/1/2011 Email from Travis Giggy to supernotes@hotmail.com re: Your No Objection LegalZoom review 11/30/2011 Email from Travis Giggy to Monique (monique@giggy.com) and Kevin Objection: E-mails Authored King re: Wideframes needed for LegalSpring by Travis Giggy Are Hearsay; Foundation Date Identified Date Admitted 6 of 25 EXHIBIT A -7- No. of Exhibit Offering Party/Parties 115 Defendant 116 Defendant GIG02064 GIG02064 117 Defendant GIG02195 GIG02195 118 Defendant GIG02355 GIG02355 119 Defendant GIG01785 GIG01788 120 Defendant GIG02079 GIG02079 121 Defendant GIG02113 GIG02114 122 Defendant GIG02230 GIG02231 123 Defendant GIG02232 GIG02232 124 Defendant LZ000909 LZ000909 125 Defendant LZ000911 LZ000911 126 Defendant LZ000912 LZ000914 127 Defendant LZ000933 LZ000936 128 Defendant LZ001537 LZ001537 Non Offering Party's Date Identified Objections 10/00/2011 Print-out from LegalSpring's website regarding LegalZoom Reviews and Objection: Hearsay; Company Information Foundation; Relevance 1/17/2012 Email from Lisette Howard to Travis Giggy re: Setting up Incorporation Objection: Hearsay; Foundation; Relevance 7/24/2012 Email from Travis Giggy to Mark (mystermr2003@yahoo.com) re: I have Objection: E-mails Authored a question for the Legal Spring webmaster by Travis Giggy Are Hearsay; Foundation 1/2/2009 Email from Travis Giggy to Kirk Stone re: Not cool Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation 9/7/2011 Email from Matt Withers to Travis Giggy, Eddie Hartman, and Brandon Objection: Hearsay; Molina re: Rocket Lawyer Funding Foundation; Relevance 1/30/2012 Email from Peter Prucnel to Travis Giggy, cc. Scott MacDonell, Carter Objection: E-mails Authored Gaffney, Patty Chikamagalur, Jeremy Vernassal, and Carrie Yutzy re: I by Travis Giggy Are Hearsay; have a question about Legal Spring Foundation 2/15/2012 Email from Travis Giggy to Bobbi Perreault re: LS review update sql Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation; Relevance 9/20/2012 Email from Carrie Yutzy to Travis Giggy re: FW: Older LegalSpring No Objection Review 9/20/2012 Email from Patty Chikamagalur to Travis Giggy re: Older LegalSpring Objection: E-mails Authored Review by Travis Giggy Are Hearsay; Foundation Objection: Hearsay; 5/24/2011 Email from Travis Giggy to Brandon Molina and Eddie Hartman re: Foundation Fwd: Rocket Lawyer 5/25/2011 Email from Travis Giggy to Matt Withers re: Fwd: Rocket Lawyer Objection: E-mails Authored by Travis Giggy Are Hearsay; Foundation Objection: Hearsay; Relevance 5/26/2011 Email from Travis Giggy to Matt Withers and Eddie Hartman re: Fwd: Rocket Lawyer 9/7/2011 Email from Matt Withers to Travis Giggy, Eddie Hartman, and Brandon Objection: Hearsay; Molina re: Rocket Lawyer Funding Incomplete; Relevance 5/24/2011 Email from Eddie Hartman to Travis Giggy re: Rocket Lawyer Objection: Hearsay; Relevance 129 130 Defendant Defendant NA RLI0037146 NA RLI0037148 5/10/2012 9/24/2012 131 132 133 Defendant Defendant Defendant RLI0037159 RLI0037696 RLI0007924 RLI0007925 RLI0006636 RLI0037159 RLI0037696 RLI0007924 RLI0007925 RLI0006636 8/28/2012 1/27/2011 NA 134 963958.1 Beg. Bates End Bates GIG01934 GIG01934 Date Description Defendant RLI0007918 RLI0007922 RLI0007918 RLI0007922 NA LegalZoom.com, Inc.'s Form S-1 Filing Email from David Baga to Michael Nelson, cc. Jarred Colli re: Incorporation Ad without Free Email from David Baga to Jarred Coli re: Ad Test Update Email from Mark Kaufman to Pete Franco re: LegalZoom's Checkout Exhibit F to the June 30, 2014 Declaration of Hong-An Vu in Support of Rocket Lawyer Incorporated's Motion for Summary Judgment and/or Adjudication - charts with Rocket Lawyer's business formation (i.e. incorporation and LLC) advertisement and conversion data from documents produced in Excel format Exhibit K to the June 30, 2014 Declaration of Hong-An Vu in Support of Rocket Lawyer Incorporated's Motion for Summary Judgment and/or Adjudication - chart with Rocket Lawyer's free trial advertisement and conversion data from documents produced in Excel format Date Admitted Objection: Relevance Objection: Incomplete Objection: Incomplete Objection: Lacks Personal Knowledge Objection: Lacks Personal Knowledge 7 of 25 EXHIBIT A -8- No. of Exhibit Offering Party/Parties 135 Defendant 136 Defendant RLI0041618 RLI0041618 137 Defendant RLI0044182 RLI0044183 138 Defendant RLI0050135 RLI0050136 139 Defendant NA NA 140 141 Defendant Defendant RLI0050359 RLI0051655 RLI0050359 RLI0051655 142 143 144 Defendant Defendant Defendant RLI0051661 RLI0051667 RLI0051764 RLI0051661 RLI0051667 RLI0051764 Non Offering Party's Objections 1/2/2014 Exhibit M to the June 30, 2014 Declaration of Hong-An Vu in Support of Objection: Lacks Personal Rocket Lawyer Incorporated's Motion for Summary Judgment and/or Knowledge Adjudication - screenshots of LegalZoom's free trial advertisements on www.legalzoom.com NA Spreadsheet providing information regarding advertisements with state fees, no state fees, and site links 10/20/2011 Email from Alisa Weiner to Michael Nelson, Rob Elhardt, and Matt Kaufman, cc. Sasha Volkov and Pete Franco re: Who owns LegalSpring.com 10/4/2012 Email from Alisa Weiner to Jarred Coli re: Updates on Free Ads Language 6/27/2014 Exhibit N to the June 30, 2014 Declaration of Hong-An Vu in Support of Objection: Lacks Personal Rocket Lawyer Incorporated's Motion for Summary Judgment and/or Knowledge Adjudication - Google and Bing instructions regarding keyword advertisements on Google and Bing, respectively, and Google and Bing search results for the keyword "incorporation" NA Spreadsheet regarding Tranche Analysis Objection: Illegible 10/24/2011 Email from Sasha Volkov to Pete Franco re: Follow-up: LegalSpring + Legalcenterpro; CR downward trend 10/00/2011 PowerPoint regarding Purchase Page Design 9/30/2011 Email from Mike N. to Pete Franco re: Funny LZ Ads NA Screenshot regarding "Select a processing option for your new business" 145 146 Defendant Defendant RLI0051765 RLI0051784 RLI0051765 RLI0051785 NA 5/20/2011 147 148 Defendant Defendant NA RLI0052984 NA RLI0052985 10/17/2013 11/21/2011 149 150 151 152 153 Defendant Defendant Defendant Defendant Defendant RLI0053354 RLI0053385 RLI0053580 RLI0057292 RLI0061998 RLI0053354 RLI0053385 RLI0053580 RLI0057292 RLI0062001 NA 8/00/2010 12/00/2011 NA 11/16/2012 154 Defendant RLI0065633 RLI0065634 5/9/2012 155 Defendant RLI0066990 RLI0066992 10/21/2011 156 157 158 159 160 161 963958.1 Beg. Bates End Bates NA NA Date Description Defendant Defendant Defendant Defendant Defendant Defendant RLI0082569 RLI0079561 3QD0000363 3QD0000766 3QD0001289 3QD0002556 RLI0082569 RLI0079622 3QD0000363 3QD0000768 3QD0001290 3QD0002556 2/13/2013 5/15/2012 5/31/2011 4/3/2012 8/28/2012 NA Date Identified Date Admitted Screenshot regarding "Purchase Summary" Email from Chris Innes to Pete Franco re: PROOF: Rocket Lawyer 160x600 Order re: Plaintiff's Motion for Summary Judgment Email from Nathaniel Alexander to David Baga, cc. Gani Urgino re: Objection: Hearsay Fwd: Rocket Lawyer - Incorporation Follow UP Spreadsheet listing "incorporation" keywords PowerPoint regarding Incorporation Business Analysis PowerPoint regarding Marketing Competitive Analysis Rocket Lawyer screenshot regarding "Incorporate for Free" Undated Email from Acquisition (noreply@google.com) to phollerbach@rocketlawyer.com re: [Acquisition] A new post was made to Monthly Updates Email from Charley Moore to Jarred Colli, cc. Pete Franco, Dan Nye, David Baga, Alisa Weiner, Sasha Volkov, and Amir Khorram re: Incorp space is getting more competitive Email from Alisa Weiner to David Baga, cc. Dan Nye, Charles Moore, and Execs re: LegalZoom competitive activity Email from David Drummond to Charley Moore re: Follow up PowerPoint slides regarding Rocket Lawyer Board Meeting Email from Bob Sturges to himself re: PPCA Call 5/31 Objection: Hearsay Email from David Baga to Gordon Khoo re: New Ad Copy Email from David Baga to Gordon Khoo re: Ad Test Update Spreadsheet with various tabs entitled "Notes from Meeting INC", "Ad Test", "NPO Data", "Frequency Cap Data", "RL Docs Meeting", and "RL UK" 8 of 25 EXHIBIT A -9- No. of Exhibit Offering Party/Parties 162 Defendant Beg. Bates End Bates 3QD0002587 3QD0002590 163 164 165 RLI0003225 RLI0045693 RLI0007916 RLI000225 RLI0045693 RLI0007916 166 Defendant RLI0007917 RLI0007917 167 Defendant RLI0007918 RLI0007918 168 Defendant RLI0007919 RLI0007919 169 Defendant RLI0007920 RLI0007920 170 Defendant RLI0007921 RLI0007921 171 Defendant RLI0007922 RLI0007922 172 Defendant RLI0007923 RLI0007923 173 Defendant RLI0007924 RLI0007924 174 Defendant RLI0007925 RLI0007925 175 176 Defendant Defendant RLI0036635 RLI0036636 RLI0036635 RLI0036636 177 Defendant RLI0036637 RLI0036638 178 Defendant NA NA 179 963958.1 Defendant Defendant Defendant Defendant NA NA Date Description Non Offering Party's Objections Date Identified Date Admitted 11/16/2012 Email from Gordon Khoo to Bailey Lau re: Weekly Call Notes 11.16.2012 NA Spreadsheet regarding calls by disposition NA Spreadsheet regarding membership cancellation NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tabs entitled "Free Legal Help" and Legal Zoom Keywords" NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tab entitled "Ad performance reports (7).csv" NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tabs entitled "Free Trial" and Legal Zoom Keyword - Free Trial" NA Report Regarding Free Help From Local Attorneys - Rocket Lawyer March 2011 through September 2013. Spreadsheet has tabs entitled "Free Help" and "Free Help - Legal Zm KW" NA Free Legal Help Report - Rocket Lawyer March 2011 through September 2013. Spreadsheet has tabs entitled "Free Legal Help" and "Free Legal Help - Legal Zoom KW" NA Report Regarding Free Legal Review - Rocket Lawyer March 2011 through September 2013. Spreadsheet has tabs entitled "Free Legal Review" and "Free Legal Review - Legal Zm KW" NA Free Trial Ad Copy Report - Rocket Lawyer March 2011 through December 2011. Spreadsheet has tabs entitled "Free Trial Ad Copy" and "Legal Zoom Keywords" NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tab entitled "Ad performance reports (7).csv" NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tabs entitled "Business Formation - Inc Acct", "Legal Zoom Keywords", "Legal Zoom Kws - No State Fee", "Legal Zoom Kws - + State Fee" NA Report regarding Bing Business Formation - All Free Ads - March 2011 through September 2013. Spreadsheet has tabs entitled "Business Formation - Free", "Legal Zoom Keywords", "Legal Zoom KWs - State Fee", "Legal Zoom KWs - No State Fee" NA Rocket Lawyer Incorporated - Financial Performance by Quarter NA Ad performance report for November 1, 2008 through September 30, 2013. Spreadsheet has tabs entitled "Google RL Search (All Free)", "Google RL Search (LZ Free)", "Bing RL Search All Free", and "Bing RL Search (LZ Free) NA Rocket Lawyer's business formation revenue from November 2008 through September 2013. 12/3/2012 Exhibit 2 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Relevance Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of Rocket Lawyer's free immigration forms 9/21/2013 Exhibit 3 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of Rocket Lawyer's free legal dictionary 9 of 25 EXHIBIT A -10- No. of Exhibit Offering Party/Parties 180 Defendant Beg. Bates End Bates Date Description Non Offering Party's Objections NA NA 12/7/2012 Exhibit 4 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the free articles available on rocketlawyer.com 181 NA NA 12/6/2012 Defendant NA NA 12/6/2012 Exhibit 6 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the Basic Legal Plan free trial registration page 183 Defendant NA NA 9/9/2013 184 Defendant NA NA 12/3/2012 185 Defendant NA NA 8/27/2013 186 Defendant NA NA 12/3/2012 187 Defendant NA NA 12/3/2012 Exhibit 7 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the FAQ regarding Rocket Lawyer's free trial plans Exhibit 8 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the option to enroll in a free trial of the pro legal plan at the end of the document interview for the incorporation process Exhibit 9 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of one of Rocket Lawyer's disclosures of state fees available on Rocketlawyer.com prior to the incorporation interview program Exhibit 10 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Relevance; Support of Rocket Lawyer's Opposition to Motion for Summary Incomplete Judgment - screenshot of Rocket Lawyer's disclosure of state and county fees in the incorporation interview Exhibit 11 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Relevance; Hearsay Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of a payment page at the end of an incorporation interview, disclosing fees and other information services purchased by a user but evidencing no charges for Rocket Lawyer's processing and filing of incorporation forms when enrolled in a free trial of the Pro Legal Plan 188 Defendant NA NA 9/9/2013 189 Defendant NA NA 12/3/2012 190 Defendant NA NA 9/9/2013 Date Admitted Exhibit 5 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the Pro Legal Plan free trial registration page 182 963958.1 Defendant Date Identified Exhibit 12 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - Rocket Lawyer's current On Call Terms and Conditions, which have been in effect since February 2013 Exhibit 13 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - Rocket Lawyer's On Call Terms and Conditions that were in effect between November 28, 2012 and February 2013 Exhibit 14 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of a search on Google.com for "legal documents" Objection: Foundation 10 of 25 EXHIBIT A -11- No. of Exhibit Offering Party/Parties 191 Defendant Beg. Bates End Bates Date NA NA 8/28/2013 192 NA NA 8/28/2013 193 Defendant NA NA 8/26/2013 194 Defendant NA NA 9/5/2013 195 Defendant NA NA 9/5/2013 196 Defendant NA NA 8/26/2013 197 Defendant NA NA 9/14/2013 198 Defendant NA NA 9/11/2013 199 Defendant NA NA 9/6/2013 200 Defendant NA NA 9/6/2009 201 Defendant NA NA 9/6/2013 202 963958.1 Defendant Defendant NA NA 3/12/2013 Description Exhibit 15 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of a search on Google.com for "incorporation" Exhibit 16 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshots of Lawdepot.com with similar services to those of Rocket Lawyer and LegalZoom Exhibit 17 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of LegalZoom's package of real estate documents Exhibit 18 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of LegalZoom's personal plan Exhibit 19 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of LegalZoom's business plan Exhibit 20 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of LegalZoom's "how it works" page showing its postal mail, hard-copy process Exhibit 23 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot from LegalZoom's pricing for incorporation Exhibit 24 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - LegalZoom's Supplemental Terms of Service for Corporate Center Exhibit 25 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - LegalZoom's webpage relating to incorporation that contains a statement regarding its "A" rating with the Better Business Bureau Non Offering Party's Objections Objection: Foundation Date Identified Date Admitted Objection: Foundation Objection: Foundation Objection: Foundation Objection: Foundation Objection: Foundation Objection: Foundation Objection: Foundation Objection: Foundation Exhibit 26 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Foundation Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of an article with simultaneous advertisements for Rocket Lawyer's and LegalZoom's incorporation services, where LegalZoom has published that it has an "A" Rating with the Better Business Bureau Exhibit 27 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Foundation Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - screenshot of the Better Business Bureau's website www.la.bbb.org showing no "A" rating for LegalZoom.com, Inc. Exhibit 28 to the September 23, 2013 Declaration of Hong-An Vu in Objection: Foundation Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - Article entitled "Better Business Bureau Expels Los Angeles Organization for Failure to Meet Standards" 11 of 25 EXHIBIT A -12- No. of Exhibit Offering Party/Parties 203 Defendant Beg. Bates End Bates Date NA NA 9/11/2013 204 NA NA 9/16/2011 205 Defendant NA NA 9/14/2013 206 Defendant NA NA NA 207 Defendant NA NA Defendant NA NA 1074 Defendant NA NA 1079 Defendant NA NA 1077 Defendant NA NA 1080 Defendant NA NA 213 Defendant NA NA 1082 Defendant NA NA 1075 Defendant NA NA 1078 Defendant NA NA 1081 Defendant NA NA Exhibit 29 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - email from Karen S. (Council of Better Business Bureaus, Inc.) to Hong-An Vu re: BBB LA Ratings Exhibit 30 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - Article entitled "LegalZoom Takes New Twist to Old Profession" Exhibit 31 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - blog entry from June 2013, found at http://iterationz.com/2013/06/25/creating-a-formal-business-structurewith-the-help-of-online-legal-services/, comparing Rocketlawyer.com and LegalZoom.com Exhibit 32 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - image of the analysis of LegalZoom's incorporation page, found at http://iterationz.files.wordpress.com/2013/06/legalzoom1_2.png NA 1076 963958.1 Defendant Description Exhibit 33 to the September 23, 2013 Declaration of Hong-An Vu in Support of Rocket Lawyer's Opposition to Motion for Summary Judgment - image of the analysis of Rocket Lawyer's incorporation page, found at http://iterationz.files.wordpress.com/2013/06/rocketlawyer1_4.png 9/23/2013 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's First Set of Requests for Admission 9/23/2013 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's First Set of Requests for Production of Documents and Things (Nos. 155) 12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Plaintiff's First Set of Requests for Production of Documents and Things (Nos. 1-55) 10/11/2013 Defendant's Objections and Responses to Plaintiff's Second Set of Requests for Production of Documents and Things (Nos. 56-59) 12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Plaintiff's Second Set of Requests for Production of Documents and Things (Nos. 56-59) 2/24/2014 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's Third Set of Requests for Production of Documents and Things (Nos. 6089) 7/21/2014 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Plaintiff's Third Set of Requests for Production of Documents and Things (Nos. 60-89) 9/23/2012 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's First Set of Special Interrogatories 12/3/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Plaintiff's First Set of Special Interrogatories 12/20/2013 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Interrogatory No. 24 Non Offering Party's Objections Objection: Hearsay Date Identified Date Admitted Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance 12 of 25 EXHIBIT A -13- No. of Exhibit Offering Party/Parties 218 Defendant Beg. Bates End Bates NA NA Date 6/18/2014 Rocket Lawyer Incorporated's Second Supplemental Objections and Responses to Plaintiff's First Set of Special Interrogatories 2/24/2014 Rocket Lawyer Incorporated's Objections and Responses to Plaintiff's Second Set of Special Interrogatories 7/21/2014 Rocket Lawyer Incorporated's Supplemental Objections and Responses to Plaintiff's Second Set of Special Interrogatories 9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First Set of Requests for Admission 8/19/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's Second Set of Requests for Admission 9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's First Set of Requests for Production 12/3/2013 LegalZoom.com, Inc.'s Supplemental Response to Rocket Lawyer Incorporated's First Set of Requests for Production 9/23/2013 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's Second Set of Requests for Production 12/3/2013 LegalZoom.com, Inc.'s Supplemental Response to Rocket Lawyer Incorporated's Second Set of Requests for Production 7/31/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's Third Set of Requests for Production 7/31/2014 LegalZoom.com, Inc.'s Response to Rocket Lawyer Incorporated's Second Set of Special Interrogatories 10/21/2014 Spreadsheet regarding Zoom keyword performance report based on dates in Ex. 22 and deposition testimony from Mr. Quispe, Tr. 80:14-83:11 1083 Defendant NA NA 220 Defendant NA NA 221 Defendant NA NA 222 Defendant NA NA 223 Defendant NA NA 224 Defendant NA NA 225 Defendant NA NA 226 Defendant NA NA 227 Defendant NA NA 228 Defendant NA NA 229 Defendant NA NA 1041-1048* Defendant NA NA 4/15/2014 231 Defendant NA NA 4/15/2014 232 Defendant NA NA 4/15/2014 233 Defendant NA NA 4/15/2014 234 Defendant NA NA 4/15/2014 235 Defendant NA NA 4/15/2014 236 963958.1 Description Defendant NA NA 4/15/2014 Exhibits 2-9 to the Expert Report Submitted by Dr. Bruce Isaacson Measuring the Impressions Conveyed by Materials Advertising Rocket Lawyer Table B: Summary of Results from Question 1 and Question 2 from the Expert Report Submitted by Dr. Bruce Isaacson Measuring the Impressions Conveyed by Materials Advertising Rocket Lawyer Table C: Summary of Responses to Questions about Ads (Questions 3 and 4) from the Expert Report Submitted by Dr. Bruce Isaacson Measuring the Impressions Conveyed by Materials Advertising Rocket Lawyer Table D: Summary of Responses to Questions About Website Pages (Questions 5, 6, 7, and 8) from the Expert Report Submitted by Dr. Bruce Isaacson Measuring the Impressions Conveyed by Materials Advertising Rocket Lawyer Appendix E Bill of Sale - Test Control Stimuli from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix E Divorce Settlement Agreement - Test Control Stimuli from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Non Offering Party's Objections Objection: Relevance Date Identified Date Admitted Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Relevance Objection: Foundation; Hearsay Objection: Foundation; Hearsay Appendix E Incorporation - Test Control Stimuli from the Expert Report Objection: Foundation; of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Hearsay Rocket Lawyer's Advertisement and Website 13 of 25 EXHIBIT A -14- No. of Exhibit Offering Party/Parties 237 Defendant Beg. Bates End Bates Date NA NA 4/15/2014 238 NA NA 4/15/2015 239 Defendant NA NA 4/15/2014 240 Defendant NA NA 4/15/2014 241 Defendant NA NA 4/15/2014 242 Defendant NA NA 4/15/2014 243 Defendant NA NA 4/15/2014 244 Defendant NA NA 4/15/2014 245 Defendant NA NA 4/15/2014 246 Defendant NA NA 4/15/2014 247 Defendant NA NA 4/15/2014 248 Defendant NA NA 4/15/2014 249 Defendant NA NA 4/15/2014 250 Defendant NA NA 4/15/2014 251 963958.1 Defendant Defendant NA NA 4/15/2014 Description Appendix E Lease Agreement - Test Control Stimuli from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix E Power of Attorney - Test Control Stimuli from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix F - LegalZoom free trial advertisement from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix F - Capture of LegalZoom free trial from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Non Offering Party's Objections Objection: Foundation; Hearsay Date Identified Date Admitted Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Appendix F - LegalZoom free trial offer from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix G - Online Legal Services Study - Online Screener Questionnaire from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix H - Online Legal Study - Screening Results from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix I - Verbatim Responses from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix L - Computer Cross Tabulation from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix L - Consumer Services Decision Tree Tables from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix L - Incorporation Services Decision Tree Tables from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Appendix M - Statistical Analysis - Results for the Consumer Perception of Rocket Lawyer's Advertisement Incorporation Services from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Objection: Foundation; Hearsay Incorporation and online legal services results table from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Sample size chart from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Stimuli test and control comparisons from the Expert Report of Professor Jerry (Yoram) Wind Regarding Consumer Perceptions of Rocket Lawyer's Advertisement and Website Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Foundation; Hearsay 14 of 25 EXHIBIT A -15- No. of Exhibit Offering Party/Parties 252 Defendant Beg. Bates End Bates Date NA NA 5/15/2014 253 NA NA 6/27/2014 254 Defendant NA NA Defendant NA NA 256 1026* 258 Defendant Defendant Defendant RLI0036800 RLI0039562 RLI0039522 RLI0036802 RLI0039565 RLI0039524 259 Defendant RLI0042326 RLI0042327 260 Defendant RLI0042332 RLI0042333 1020* Defendant RLI0042339 RLI0042340 1022 263 Defendant Defendant RLI0042345 RLI0042523 RLI0042347 RLI0042523 264 Defendant RLI0065734 RLI0065737 265 Defendant RLI0065741 RLI0065743 266 Defendant RLI0065758 RLI0065760 267 Defendant RLI0066972 RLI0066974 1011* Defendant RLI0039820 RLI0039820 1012* Defendant RLI0042598 RLI0042620 270* Defendant RLI0040722 RLI0040726 271 Defendant RLI0042638 RLI0042641 272 Defendant RLI0048851 RLI0048851 273 Defendant RLI0083881 RLI0083881 Exhibits A-F to the Rebuttal Report of Professor Yoram (Jerry) Wind in Response to Report of Dr. Bruce Isaacson Chart regarding The Relationship between Intention to Buy and Actual Purchase from the Supplemental Report of Yoram (Jerry) Wind 6/27/2014 255 963958.1 Defendant Description Appendix A- Results Tables from the Supplemental Report of Yoram (Jerry) Wind 6/27/2014 Appendix B - Statistical Analysis from the Supplemental Report of Yoram (Jerry) Wind 4/10/2013 Email from John Whelan to Brian Kocher re: Incorporation 11/18/2011 Email from Brian Liu to Charley Moore re: Google Ads 12/11/2011 Email from Executive Team (noreply@google.com) to Charley Moore re: [Executive Team] 2011-12-05 was updated 12/7/2011 Email from Christian Knuetter to Dan Nye, cc. Alisa Weiner, Charles Moore, David Baga, John Whelan, and An Tran re: LegalZoom Attack Non Offering Party's Objections Objection: Foundation; Hearsay Objection: Foundation; Hearsay Date Identified Date Admitted Objection: Foundation; Hearsay Objection: Foundation; Hearsay Objection: Relevance 12/7/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Policy Objection: Hearsay; Relevance Follow Up 12/2/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket Lawyer Follw Up 12/1/2011 Email from Charley Moore to Alisa Weiner re: Policy Issues 10/20/2011 Email from Katherine K. to Michael Nelson, cc. Sasha Volkov and Alisa Objection: Hearsay Weiner re: Policy Follow Up 12/13/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket Lawyer Follw Up 12/8/2011 Email from David Baga to Charley Moore, cc. Christian Knuetter, Dan Objection: Relevance Nye, Alisa Weiner, John Whelan, and An Tran re: LegalZoom Attack 12/5/2011 Email from Katherine K. to Charley Moore, cc. Alisa Weiner re: Rocket Lawyer Follow Up 12/6/2011 Email from Alisa Weiner to Charley Moore, cc. Dan Nye, Courtney O'Connell, David Baga, An Tran, Christian Knuetter, David Kreitzer and Pete Franco re: Fwd: Rocket Lawyer Follow Up 4/16/2010 Interviews from Ferguson's April 2010 study Objection: Incomplete; Hearsay; Lack of Knowledge; Misleading 10/17/2011 Email from Jenny Dearing to Michael Margolis, cc. Kevin McSpadden, Objection: Incomplete; John Fernandes, Alisa Weiner, and Sasha Volkov re: Notes from UX Hearsay; Misleading interviews 1-4. Notes pertaining to usability interviews is attached NA Notes pertaining to usability interviews. Objection: Incomplete; Hearsay; Misleading 10/10/2011 Email from Michael Margolis to Alisa Weiner, cc. ThinkBrandNew, John Zeratsky, and Jenny Dearing re: Connecting 2/17/2011 PowerPoint slides regarding Rocket Lawyer's Board of Directors Meeting 4/15/2010 PowerPoint slides regarding Rocket Lawyer's Board of Directors Meeting 15 of 25 EXHIBIT A -16- No. of Exhibit Offering Party/Parties 274 Defendant Beg. Bates End Bates NA NA 275 Defendant NA NA 276 Defendant NA NA 277 Defendant NA NA 278 Defendant NA NA 279 Defendant NA NA 280 Defendant N/A N/A 281 Defendant RLI0044139 RLI0044139 282 Defendant NA NA 283 284 Defendant Defendant NA NA NA NA 285 Defendant NA NA 286 287 288 Defendant Defendant Defendant NA NA NA 289 Defendant 290 Date Description Non Offering Party's Date Identified Objections Objection: Relevance; Hearsay 10/24/2014 Screenshot of the Business Consumer Alliance's review of LegalZoom.com found at http://www.businessconsumeralliance.org/report/legalzoomcominc13156151 10/24/2014 Screenshot of the Business Consumer Alliance's review of Rocket Objection: Relevance; Hearsay Lawyer Corporate Services LLC found at http://www.businessconsumeralliance.org/report/rocket-lawyer-corporateservices-llc-104856689 10/24/2014 Top Ten Reviews for Rocket Lawyer found at http://online-legal-forms- Objection: Relevance; Hearsay review.toptenreviews.com/rocket-lawyer-review.html 10/24/2014 Top Ten Reviews for LegalZoom.com found at http://online-legal-forms- Objection: Relevance; Hearsay review.toptenreviews.com/legalzoom-review.html NA Placeholder for the demo video of the consumer flow Objection: Relevance; Foundation; Hearsay NA Undisputed Statements of Fact for Summary Judgment Not Disputed or Not Properly Disputed Rocket Lawyer's Answer to First Amended Complaint and Amended Counterclaims 11/7/2011 Email from Alisa Weiner to coconnell@rocketlawyer.com re: 1:1 videos NA NA NA Rocket Lawyer, Inc.'s Initial Disclosures Purusant to Fed. R. Civ. Proc. 26(A)(1) 9/20/2013 Amended Rule 26(A)(1) Disclosures of Rocket Lawyer Incorporated 10/24/2014 Rocket Lawyer, Inc.'s Second Amended Disclosures Pursuant to Fed. R. Civ. Proc. 26(A)(1) 4/8/2013 LegalZoom.com, Inc.'s Initial Disclosures Pursuant to Fed. R. Civ. P. 26(A)(1) 9/26/2013 LegalZoom.com, Inc.'s Amended Rule 26(A)(1) Disclosures 10/24/2014 LegalZoom.com, Inc.'s Supplemental Rule 26(A)(1) Disclosures 10/27/2014 Historic screenshots from LegalCenterPro.com Objection: Relevance; Hearsay NA NA 10/27/2014 Historic screenshots from LegalSpring.com Objection: Relevance; Hearsay Defendant RLI0003391 RLI0003391 8/12/2010 Objection: Relevance; Hearsay 291 Defendant RLI0074319 RLI0074319 3/14/2013 292 Defendant RLI0083634 RLI0083634 6/29/2011 293 Defendant RLI0083880 RLI0083881 4/14/2010 294 Defendant NA NA 1001 Plaintiff 1002 963958.1 Date Admitted 4/8/2013 Plaintiff NA Rocket Lawyer PowerPoint presentation entitled "Incorporation Business Analysis" Rocket Lawyer PowerPoint presentation entitled "Incorporation Business Update" Rocket Lawyer PowerPoint slides entitled "Actual & Projected Customer Lifetime Value (LTV)" and "Traffic Distribution" Email from Charles Moore to Dan Nye and Jeff Wheeler re: BOD Slides 04-15-10 draft v4.pptx. Attached to the email is a Rocket Lawyer PowerPoint presentation entitled "Board of Directors Meeting April 15, 2010" Screenshots of Websites Advertising "Free" Objection: Relevance; Hearsay Objection: Relevance; Hearsay Objection: Relevance; Hearsay Objection: Relevance; Hearsay Rocket Lawyer advertisement on Google.com featuring “Incorporate for Free…Pay No Fees ($0).” Rocket Lawyer advertisement on Yahoo featuring “Zoom Charges $99, We’re Free.” 16 of 25 EXHIBIT A -17- No. of Exhibit Offering Party/Parties 1003 Plaintiff Beg. Bates End Bates 1004 1005 Plaintiff 1006 1007 Plaintiff Plaintiff RLI 0036654 RLI 0040580 RLI 0040632 1008 Plaintiff RLI 0040744 RLI 0040744 1009 Plaintiff RLI 0040687 1010 Plaintiff RLI 0040728 1011 Plaintiff RLI 0039820 1012 Plaintiff RLI 0042598 1013 1014 963958.1 Plaintiff Plaintiff Plaintiff RLI 0005804 RLI 0036680 Date Description Non Offering Party's Objections Date Identified Date Admitted Rocket Lawyer advertisement on Yahoo featuring “Zoom Costs $99, We’re Free.” Rocket Lawyer advertisement on Google featuring “Free Legal Forms & LLC’s” from Rocket Lawyer Rocket Lawyer advertisement on Rocketlawyer.com featuring “Free help from local attorneys.” Freemium Yellow Brick Road presentation/document 4/0/2010 Rocket Lawyer Usability Research April 2010 Hearsay, FRE 801; research participants and Ferguson not available to testify; prejudicial, FRE 403, jury may be led to believe it is an actual consumer survey 10/0/2010 Rocket Lawyer Usability Research October 2010 [Produced in Native Hearsay, FRE 801; research Format] participants and Ferguson not available to testify; prejudicial, FRE 403, jury may be led to believe it an actual consumer survey 6/0/2011 Rocket Lawyer Detailed Usability Findings Small Business Owner and Hearsay, FRE 801; research Consumer Research June 2011 participants and Ferguson not available to testify; prejudicial, FRE 403, jury may be led to believe it is an actual consumer survey 10/21/2011 Rocket Lawyer: UX Research Toplines October 21, 2011 Hearsay, FRE 801; research participants and Margolis not available to testify; prejudicial, FRE 403, jury may be led to believe it is an actual consumer survey 4/0/2010 Handwritten Notes from April 2010 Usability Study – Author Unknown Hearsay, FRE 801; research participants and Margolis not available to testify; prejudicial, FRE 403, jury may be led to believe it is an actual consumer survey Handwritten Notes from UX Interviews – Author Jenny Dearing of Hearsay, FRE 801; research Thinkbrandnew.com participants and Margolis not available to testify; prejudicial, FRE 403, jury may be led to believe it is an actual consumer survey 10/15/2012 Email from Justin Tenuto to Jarrad Colli 10/23/2012 Email from Chris Faville to Alisa Weiner Hearsay, FRE 801, to the extent to show that people are getting confused with RLI's UI. 17 of 25 EXHIBIT A -18- No. of Exhibit Offering Party/Parties 1015 Plaintiff Beg. Bates End Bates Date Description RLI 0036803 2/5/2013 Email from John Whelan to Chris Faville 1016 RLI 0037960 7/20/2010 Email from David Baga to Jennifer Paulus 1017 Plaintiff RLI 0037987 7/21/2010 Email from Eric Geibel to David Baga 1018 963958.1 Plaintiff Plaintiff RLI 0037098 8/17/2010 Non Offering Party's Date Identified Objections Hearsay, FRE 801, to extent LZ offers customer responses to show actual customer confusion; prejudicial, FRE 403; irrelevant 401, 402 ("a handful of customer statements on one online review site is not sufficient to demonstrate that a 'significant portion' of customers were deceived and is not necessarily a reliable consumer survey or market research" SJ Order. ECF 44 AT 10. Hearsay, FRE 801, to extent LZ offers customer response to show actual customer confusion; prejudicial, FRE 403; irrelevant 401, 402 ("a handful of customer statements on one online review site is not sufficient to demonstrate that a 'significant portion' of customers were deceived and is not necessarily a reliable consumer survey or market research" SJ Order. ECF 44 AT 10. Hearsay, FRE 801, to extent LZ offers customer response to show actual customer confusion; prejudicial, FRE 403; irrelevant 401, 402 ("a handful of customer statements on one online review site is not sufficient to demonstrate that a 'significant portion' of customers were deceived and is not necessarily a reliable consumer survey or market research" SJ Order. ECF 44 AT 10. Date Admitted Email from Jenn Mazzon to David Baga 18 of 25 EXHIBIT A -19- No. of Exhibit Offering Party/Parties 1019 Plaintiff Beg. Bates End Bates Date Description RLI 0001021 4/30/2012 Email from Pete Franco to Mike N 1020 RLI 0042339 12/2/2011 Email from Katherine K. of Google to Charley Moore 1021 1022 1023 1024 Plaintiff Plaintiff Plaintiff Plaintiff RLI 0042354 RLI 0042345 RLI 0037788 RLI 0049002 12/1/2011 12/1/2011 12/14/2010 1/29/2011 Email from Michael Nelson to Sasha Volkov Email from Charley Moore to Alisa Weiner Email from David Baga to Dave Yoo Email from Jenn Mazzon to Rebecca Carpenter 1025 1026 1027 1028 1029 1030 Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff RLI 0039576 RLI 0039562 RLI0037010 11/16/2011 11/18/2011 12/12/2011 9/23/2014 10/1/2014 9/23/2013 1031 1032 1033 1034 1035 Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff 1036 1037 Plaintiff Plaintiff 4/15/2014 Email between Brian Liu and Charley Moore Email between Brian Liu and Charley Moore Email from Dan Nye to Charley Moore Excerpts of the Deposition of Alisa Weiner Excerpts of the Deposition of Paul Hollerbach Declaration of Paul Hollerbach In Support of Rocket Lawyer’s Opposition to Motion for Summary Judgment Excerpts of the Deposition of Mark Sedlacek Excerpts of the Deposition of Pete Franco Excerpts of the Deposition of David Baga Excerpts of the Deposition of Charley Moore LegalZoom Answer to Rocket Lawyer’s Amended Counterclaims (Docket No. 18) First Amended Complaint filed by LegalZoom (Docket No. 14) Tab No. 1 to the Expert Report of Alan Goedde, Ph.D. 1038 963958.1 Plaintiff Plaintiff 4/15/2014 Tab No. 2 to the Expert Report of Alan Goedde, Ph.D. RLI 0039577 RLI 0039565 10/1/2014 10/3/2014 10/8/2014 10/9/2014 Non Offering Party's Date Identified Objections FRE 407 – subsequent remedial measures – evidence that we changed our ads in response to pressure from LegalZoom is not admissible to prove culpable conduct or a need for a warning or instruction Incomplete, FRE 106, there are later emails with Katherine K Date Admitted The email attaches RLI October 2010 Usability Research. Hearsay, FRE 801; research participants and Ferguson not available to testify; prejudicial, FRE 403, jury may be led to believe it an actual consumer survey Hearsay, FRE 801 Hearsay, FRE 801 Hearsay, FRE 801 Hearsay, FRE 801 Hearsay, FRE 801 Hearsay, FRE 801 Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report 19 of 25 EXHIBIT A -20- No. of Exhibit Offering Party/Parties 1039 Plaintiff Beg. Bates End Bates Date Description 4/15/2014 Tab No. 3 to the Expert Report of Alan Goedde, Ph.D. Non Offering Party's Date Identified Objections Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report 1040 1041 1042 1043 1044 1045 1046 1047 1048 1049 1050 1051 1052 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/0/2014 4/15/2014 4/0/2014 4/0/2014 6/3/2014 Exhibit 1 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 2 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 3 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 4 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 5 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 6 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 7 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 8 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 9 to the Expert Report of Dr. Bruce R. Isaacson Exhibit 1 to the Expert Report of Dr. Larry Chiagouris Exhibit 2 to the Expert Report of Dr. Larry Chiagouris Exhibit 3 to the Expert Report of Dr. Larry Chiagouris Tab 1 to the Supplemental Expert Report of Alan Goedde, Ph.D. 1053 Plaintiff 6/3/2014 Tab 2 to the Supplemental Expert Report of Alan Goedde, Ph.D. Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report 1054 Plaintiff 6/3/2014 Tab 3 to the Supplemental Expert Report of Alan Goedde, Ph.D. Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report 1055 Plaintiff 10/0/2014 Part 1 to the Second Supplemental Expert Report of Alan Goedde, Ph.D. 1056 Plaintiff 10/0/2014 Part 2 to the Second Supplemental Expert Report of Alan Goedde, Ph.D. 1057 Plaintiff 10/0/2014 Part 3 to the Second Supplemental Expert Report of Alan Goedde, Ph.D 1058 Plaintiff 10/0/2014 Part 4 to the Second Supplemental Expert Report of Alan Goedde, Ph.D. 1059 1060 1061 1062 1063 963958.1 Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Plaintiff Date Admitted Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report LegalZoom’s First Request for Production of Documents LegalZoom’s Second Set of Requests for Production of Documents LegalZoom’s Third Set of Requests for Production of Documents LegalZoom’s First Set of Interrogatories to Rocket Lawyer LegalZoom’s Second Set of Interrogatories to Rocket Lawyer 20 of 25 EXHIBIT A -21- No. of Exhibit Offering Party/Parties 1064 Plaintiff 1065 Plaintiff 1066 Plaintiff 1067 Plaintiff 1068 Plaintiff 1069 Plaintiff 1070 Plaintiff 1071 Plaintiff 1072 Plaintiff 1073 Plaintiff Beg. Bates End Bates Date Non Offering Party's Objections Date Identified Date Admitted LegalZoom’s First Set of Request for Admissions to Rocket Lawyer 10/24/2014 LegalZoom’s Amended Rule 26(a)(1) Disclosures Amended Notice of Deposition of Alisa Weiner Amended Notice of Deposition of Paul Hollerbach Amended Notice of Deposition of Mark Sedlacek Amended Notice of Deposition of Pete Franco Amended Deposition Notice of David Baga Amended Deposition Notice of Charley Moore LegalZoom’s Notice of 30(b)(6) Deposition Rocket Lawyer’s Responses and Objections to LegalZoom’s Notice of 30(b)(6) Deposition Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s First Set of Requests for Production of Document and Things (Nos. 1-55) 1074 Plaintiff 1075 Plaintiff 1076 Plaintiff 1077 Plaintiff 1078 Plaintiff 1079 Plaintiff 1080 Plaintiff 1081 Plaintiff 1082 Plaintiff 1083 Plaintiff 1084 Plaintiff 9/4/2013 1085 963958.1 Description Plaintiff 9/4/2013 Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s First Set of Special Interrogatories Rocket Lawyer’s Incorporated’s Objections and Responses to Plaintiff’s First Set of Requests for Admission Defendant’s Objections and Responses to Plaintiff’s Second Set of Requests for Production and Things (Nos. 56-59) Rocket Lawyer Incorporated’s Supplemental Objections and Responses to Plaintiff’s First Set of Special Interrogatories Rocket Lawyer Incorporated’s Supplemental Objections and Responses to Plaintiff’s First Set of Requests for Production and Things (Nos. 1-55) Rocket Lawyer Incorporated’s Supplemental Objections and Responses to Plaintiff’s Second Set of Requests for Production and Things (Nos. 5659) Rocket Lawyer Incorporated’s Supplemental Objections and Responses to Interrogatory No. 24 Rocket Lawyer Incorporated Supplemental Objections and Responses to Plaintiff’s Third Set of Requests for Production of Documents and Things (Nos. 60-89) Rocket Lawyer Incorporated’s Objections and Responses to Plaintiff’s Second Set of Special Interrogatories Exhibit A to the September 4, 2013 Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Motion for Summary Judgment Exhibit B to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading, in support of Plaintiff LegalZoom’s Motion for Summary Judgment FRE 106 and 403, to that the ads that other ads that appear on search engine results are not included and to the extent that the screenshot is not clear as to whether the image shows a paid advertisement or an organic search result 21 of 25 EXHIBIT A -22- No. of Exhibit Offering Party/Parties 1086 Plaintiff Beg. Bates End Bates Date 9/4/2013 Description Non Offering Party's Date Identified Objections Exhibit C to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106; in support of Plaintiff LegalZoom’s Motion for Summary Judgment misleading, FRE 403; to extent it is offered to show the only disclosure of state filing fees on Rocketlawyer.com and only a portion of the user journey Exhibit D to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106; in support of Plaintiff LegalZoom’s Motion for Summary Judgment misleading, FRE 403; to extent it is offered to show the only disclosure of state filing fees on Rocketlawyer.com and only a portion of the use journey (missing summary of order and payment pages) Exhibit E to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106; in support of Plaintiff LegalZoom’s Motion for Summary Judgment misleading, FRE 403 to the extent that the first page is used to show what services are included in the free trial and as to the second page, it is unclear what the status of the user is at the time this screenshot was taken and the offer for free legal review was made. 1087 9/4/2013 1088 Plaintiff 9/4/2013 1089 Plaintiff 9/4/2013 Exhibit F to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading, in support of Plaintiff LegalZoom’s Motion for Summary Judgment FRE 106 and 403, 407 to the extent used to show negligence; culpable conduct; a defect in a product or its design; or a need for a warning or instruction through remedial action 1090 Plaintiff 9/4/2013 Exhibit G to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incompete and misleading, in support of Plaintiff LegalZoom’s Motion for Summary Judgment FRE 106 and 403, 407 to the extent used to show negligence; culpable conduct; a defect in a product or its design; or a need for a warning or instruction through remedial action 1091 963958.1 Plaintiff Plaintiff 9/4/2013 Date Admitted Exhibit H to the September 4, 2013 Declaration of Mary Ann T. Nguyen Incomplete, FRE 106; in support of Plaintiff LegalZoom’s Motion for Summary Judgment misleading, FRE 403 to the extent that the first page is used to show what services are included in the free trial and as to the second page 22 of 25 EXHIBIT A -23- No. of Exhibit Offering Party/Parties 1092 Plaintiff Beg. Bates End Bates Date Description 9/4/2013 Exhibit I to the September 4, 2013 Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Motion for Summary Judgment 1093 9/4/2013 Plaintiff 9/4/2013 Exhibit K to the September 4, 2013 Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Motion for Summary Judgment 1095 Plaintiff 9/4/2013 Exhibit L to the September 4, 2013 Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Motion for Summary Judgment 1096 Plaintiff 1097 Plaintiff 7/21/2014 1098 1099 Plaintiff Plaintiff 7/21/2014 1100 Plaintiff 7/21/2014 1101 Plaintiff 7/21/2014 1102 Plaintiff 7/21/2014 1103 Plaintiff 7/21/2014 Date Admitted Exhibit J to the September 4, 2013 Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Motion for Summary Judgment 1094 963958.1 Plaintiff Non Offering Party's Date Identified Objections Incompete and misleading, FRE 106 and 403, to the extent that it is offered to show that this is the only disclosure of Rocket Lawyer’s free trial terms Declaration of Mary Ann T. Nguyen in support of Plaintiff LegalZoom’s Hearsay, FRE 801, Misleading, Motion for Summary Judgment FRE 403, to the extent that it suggests that RLI charges fees outside of state processing fees or that RLI's free trial is not actually free Exhibit A to the July 21, 2014 Declaration of Patricia J. Winograd in Hearsay, FRE 801, Jerry support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Wind's deposition transcript; Incorporated’s Motion for Summary Judgment and/or Summary incomplete and thus Adjudication misleading, FRE 106 and 403 Intentionally Left Blank Exhibit B to the July 21, 2014 Declaration of Patricia J. Winograd in Misleading as to date support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer metadata has 7/20/2011 Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit C to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit D to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit E to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit F to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication 23 of 25 EXHIBIT A -24- No. of Exhibit Offering Party/Parties 1104 Plaintiff Beg. Bates End Bates Date 7/21/2014 1105 7/21/2014 1106 Plaintiff 7/21/2014 1107 Plaintiff 7/21/2014 1108 Plaintiff 7/21/2014 1109 Plaintiff 1110 963958.1 Plaintiff Plaintiff RLI0005744 RLI0005746 5/18/2011 Description Non Offering Party's Objections Exhibit G to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit H to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit I to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit J to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Exhibit K to the July 21, 2014 Declaration of Patricia J. Winograd in support of LegalZoom.com, Inc.’s Opposition to Rocket Lawyer Incorporated’s Motion for Summary Judgment and/or Summary Adjudication Email between John Whelan and Matt Kaufman re Advertisement of Rocket Lawyer On Call Date Identified Date Admitted Hearsay, FRE 801, to extent LZ offers customer response to show actual customer confusion; prejudicial, FRE 403; irrelevant 401, 402 ("a handful of customer statements on one online review site is not sufficient to demonstrate that a 'significant portion' of customers were deceived and is not necessarily a reliable consumer survey or market research" SJ Order. ECF 44 AT 10. Hearsay, 801 Hearsay, 801, Relevance, FRE 402; prejudicial, FRE 403. This version of the Goedde report has been expressly superseded by the 2nd supplemental report Hearsay, FRE 801, to extent LZ offers customer response to show actual customer confusion; prejudicial, FRE 403; irrelevant 401, 402 ("a handful of customer statements on one online review site is not sufficient to demonstrate that a 'significant portion' of customers were deceived and is not necessarily a reliable consumer survey or market research" SJ Order. ECF 44 AT 10. Demonstrative Evidence 24 of 25 EXHIBIT A -25- No. of Exhibit Offering Party/Parties 1111 Plaintiff 1112 Plaintiff 1113 Plaintiff 1114 Plaintiff 1115 Plaintiff 963958.1 Beg. Bates End Bates Date Description Non Offering Party's Objections Date Identified Date Admitted Demonstrative Evidence Demonstrative Evidence Demonstrative Evidence Demonstrative Evidence Demonstrative Evidence 25 of 25 EXHIBIT A -26-

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