LegalZoom.com Inc v. Rocket Lawyer Incorporated
Filing
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STATUS REPORT Concerning Third Party Discovery and Request for Additional Extension of Court Deadlines filed by Plaintiff LegalZoom.com Inc. (Heather, Fred)
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PATRICIA L. GLASER - State Bar No. 55668
pglaser@glaserweil.com
FRED D. HEATHER - State Bar No. 110650
fheather@glaserweil.com
AARON P. ALLAN – State Bar No. 144406
allan@glaserweil.com
GLASER WEIL FINK HOWARD AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: (310) 553-3000
Facsimile: (310) 556-2920
Attorneys for Rocket Lawyer
LegalZoom.com, Inc.
UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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LEGALZOOM.COM, INC., a Delaware
corporation
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Plaintiff,
USDC Case No: CV 12-9942 JEM
Hon. John E. McDermott
v.
STATUS REPORT CONCERNING
THIRD PARTY DISCOVERY AND
ROCKET LAWYER INCORPORATED, REQUEST FOR ADDITIONAL
a Delaware corporation
EXTENSION OF COURT
DEADLINES
Defendant.
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STATUS REPORT CONCERNING THIRD PARTY DISCOVERY AND REQUEST FOR ADDITIONAL
EXTENSION OF COURT DEADLINES
1021810.1
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TO THE HONORABLE JOHN E. MCDERMOTT AND ALL COUNSEL
OF RECORD:
WHEREAS, pursuant to a stipulation and order entered on January 20, 2015,
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this Court permitted LegalZoom additional time to pursue discovery from third
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parties, including Google and Google Ventures, and set a deadline of May 19, 2015,
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for the completion of that discovery;
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WHEREAS, the Court recognized the possibility that discovery from third
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parties might take longer than anticipated to complete, based on Google’s resistance
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to that discovery; and
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WHEREAS, the Court set a deadline of April 24, 2015, for LegalZoom to
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notify the Court and Rocket Lawyer if the completion of discovery was unlikely by
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May 19, 2015, and to file a request seeking the extension of that deadline.
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NOW, based on the above, PLEASE TAKE NOTICE:
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1.
LegalZoom has been diligently pursuing the following third party
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discovery: LegalZoom has taken the depositions of Elizabeth Ferguson, Jennifer
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Mazzon, and Alan Hungate. LegalZoom also issued two deposition subpoenas for
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records and/or testimony to Google and Michael Margolis, a principal at Google
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Ventures, pursuant to the parties stipulation and order signed on November 10, 2014,
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by Judge Feess. LegalZoom has diligently sought the whereabouts of Katherine K
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(Kramer), a former employee of Google. LegalZoom has found that she is currently a
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graduate student at Stanford University, and is working to serve her with a deposition
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subpoena.
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2.
LegalZoom filed two motions to compel compliance with a subpoena
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against Google, in the Northern District of California, and against Michael Margolis,
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in the Western District of Washington.
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3.
The motion to compel against Google was denied on March 23, 2015,
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which required LegalZoom to pursue an appeal from that denial. That appeal is still
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pending. In addition, the Western District of Washington issued a stay of its
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STATUS REPORT CONCERNING THIRD PARTY DISCOVERY AND REQUEST FOR ADDITIONAL
EXTENSION OF COURT DEADLINES
1021810.1
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proceedings until the appeal in the Northern District of California is heard, and an
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Order is issued.
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4.
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Based on the status of LegalZoom’s discovery efforts against Google, it
is not possible that discovery will be completed by the May 19, 2015 Court deadline.
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THEREFORE,
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LegalZoom respectfully requests that the Court move the deadline to complete
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third party discovery by an additional 120 days (to September 16, 2015), subject to
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any further request for extension based on how that discovery progresses over the
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next few months.
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DATED: April 15, 2015
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GLASER WEIL FINK
HOWARD AVCHEN & SHAPIRO LLP
BY: _/s/ Fred D. Heather______
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PATRICIA L. GLASER
FRED D. HEATHER
AARON P. ALLAN
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Attorneys for Plaintiff
LegalZoom.com, Inc.
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STATUS REPORT CONCERNING THIRD PARTY DISCOVERY AND REQUEST FOR ADDITIONAL
EXTENSION OF COURT DEADLINES
1021810.1
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