LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 36

AMENDED DOCUMENT filed by Defendant Rocket Lawyer Incorporated. Amendment to Disclosure 23 (Vu, Hong-An)

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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
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]
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,

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

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LIBA/2434845.1

Case No. 2:12-cv-09942-GAF-AGR
AMENDED RULE 26(A)(1)
DISCLOSURES OF ROCKET
LAWYER INCORPORATED
Judge:
Courtroom:

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

Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, Defendant

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Rocket Lawyer, Inc. (“Rocket Lawyer”), by and through its attorneys, hereby

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submits the following amended disclosures. Rocket Lawyer reserves the right to

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supplement or amend these disclosures as additional information becomes available

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during the discovery process. These amended disclosures do not waive Rocket

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Lawyer’s right to object to the disclosure of any information or documents on any

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grounds including, but not limited to, privilege, relevance, or prejudice, provided by

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the Federal Rules of Civil Procedure or the Local Civil Rules of the United States

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District Court for the Central District of California.

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I.

RULE 26(A)(1)(A)(I) – INDIVIDUALS
Rocket Lawyer amends its initial disclosure pursuant to Rule 26(a)(1)(A) as

follows:
The following individuals are likely to have discoverable information that

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Rocket Lawyer may use to support its claims or defenses, excluding persons to be

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used solely for impeachment. The subjects of discoverable information for which

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these individuals are identified are also provided. Rocket Lawyer reserves the right

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to identify additional individuals with relevant information at a later date. Rocket

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Lawyer also reserves the right to rely upon information derived from additional

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persons as such individuals come to its attention through further discovery and

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investigation, to rely upon evidence obtained from any persons identified by any

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party to this litigation and to rely upon evidence obtained from the foregoing

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individuals with respect to any subject.

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1.

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LIBA/2434845.1

Charles Moore
Founder and Executive Chairman of Rocket Lawyer
c/o Forrest A. Hainline III
[e-mail]
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111

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Paul Hollerbach
Chief Financial Officer of Rocket Lawyer
c/o Forrest A. Hainline III
[e-mail]
Goodwin Procter LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111

3.

David Baga
Senior Vice President of Revenue Operations or Rocket Lawyer
c/o Forrest A. Hainline III
[e-mail]
Goodwin Procter LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111

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The aforementioned individuals have knowledge of and are expected to

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provide information regarding Rocket Lawyer’s marketing, advertising, promotions,

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and business operations, finances, policies, and conduct.

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Dated: September 20, 2013

Respectfully submitted,

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By: /s/Hong-An Vu
Forrest A. Hainline III
[e-mail]
Michael T. Jones (SBN 290660)
[e-mail]
Hong-An Vu (SBN 266268)
[e-mail]
GOODWIN PROCTER LLP

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Attorneys for Defendant
ROCKET LAWYER INCORPORATED

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LIBA/2434845.1

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