LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 40

DISCLOSURE LEGALZOOM.COM Inc's Amended Rule 26(A)(1) Disclosures filed by Plaintiff LegalZoom.com Inc, Counter Defendant LegalZoom.com Inc (Heather, Fred)

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PATRICIA L. GLASER - State Bar No. 55668
[e-mail]
FRED D. HEATHER - State Bar No. 110650
[e-mail]
MARY ANN T. NGUYEN – State Bar No. 269099
[e-mail]
GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
LEGALZOOM.COM, INC.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WESTERN DIVISION

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LEGALZOOM.COM, INC.’S
AMENDED RULE 26(A)(1)
DISCLOSURES

Plaintiff,

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Case No. 2:12-cv-09942-GAF-AGR

LEGALZOOM.COM, INC., a Delaware
corporation,

v.

Judge:
Courtroom:

ROCKET LAWYER
INCORPORATED, a Delaware
corporation,

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Defendant.

Judge Gary A. Feess
740
255 East Temple Street
Los Angeles, CA 90012

Action Filed: November 20, 2012

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

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LegalZoom.com, Inc. (“LegalZoom” or “Plaintiff”), by and through its undersigned
counsel, hereby submits the following amended disclosures (“Amended
Disclosures”).
I.

These Amended Disclosures represent the product of LegalZoom’s

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INTRODUCTORY STATEMENT

investigation to date. Further investigation and discovery may bring light to
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LEGALZOOM.COM, INC.’S AMENDED RULE 26(A)(1) DISCLOSURES
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additional information that may have a bearing on LegalZoom’s claims and defenses

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in this matter. LegalZoom reserves the right to supplement or amend its Initial

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Disclosures and these Amended Disclosures as additional information becomes

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available to LegalZoom upon further investigation and discovery. LegalZoom’s

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disclosures are made without waiving, in any respect, the right to object the use of

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any such information, for any purpose, in whole or in part, in any subsequent state

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or proceeding in this action or any other action, or any other discovery proceeding

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involving or relating to the subject matter of these disclosures, on the grounds of

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competency, privilege, relevance, materiality, hearsay, or any other proper ground

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provided by the Federal Rules of Civil Procedure or the Local Civil Rules of the

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United States District Court for the Central District of California.
The following Amended Disclosures are made based on the information

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reasonably available to LegalZoom as of the date of these disclosures and represent

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LegalZoom’s good faith effort to identify information pertaining to the allegations

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in this litigation. LegalZoom anticipates that further investigation, research and

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analysis will supply additional facts and documents and add meaning to known

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facts, all of which may in turn lead to substantial additions or changes to these

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disclosures.
All of the disclosures set forth below are made subject to the above comments

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and qualifications.

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II.

INDIVIDUALS LIKELY TO HAVE DISCOVERABLE

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INFORMATION (RULE 26(a)(1)(A)(i))

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LegalZoom amends its Initial Disclosures pursuant to Rule 26(a)(1)(A) as

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follows:
Based upon information reasonably available to LegalZoom at this time,

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LegalZoom hereby identifies the following individuals who are likely to have

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discoverable information that LegalZoom may use to support its claims or defenses

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in this action, excluding individuals who are to be used solely for the purposes of
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LEGALZOOM.COM, INC.’S AMENDED RULE 26(A)(1) DISCLOSURES
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impeachment.

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A.

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The following current chairman of the board and employees of

LegalZoom:
1.

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Brian Liu, Chairman and Co-Founder of LegalZoom.com, Inc.;

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c/o Glaser Weil Fink Jacobs Howard Avchen & Shapiro LLP,

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10250 Constellation Boulevard, 19th Floor, Los Angeles,

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California 90067, [phone].
2.

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Dorian Quispe, Vice President, Acquisitions of LegalZoom.com,
Inc.; c/o Glaser Weil Fink Jacobs Howard Avchen & Shapiro

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LLP, 10250 Constellation Boulevard, 19th Floor, Los Angeles,

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California 90067, [phone].
3.

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Edward Hartman, Chief Strategy Officer & President, Attorney

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Services and Co-Founder of LegalZoom.com, Inc.; c/o Glaser

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Weil Fink Jacobs Howard Avchen & Shapiro LLP, 10250

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Constellation Boulevard, 19th Floor, Los Angeles, California

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90067, [phone].
4.

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Scott MacDonell, Vice President of Marketing for

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LegalZoom.com, Inc.; c/o Glaser Weil Fink Jacobs Howard

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Avchen & Shapiro LLP, 10250 Constellation Boulevard, 19th

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Floor, Los Angeles, Calfiornia 90067, [phone].
5.

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Matthew Withers, Director Affiliate Marketing for

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LegalZoom.com, Inc.; c/o Glaser Weil Fink Jacobs Howard

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Avchen & Shapiro LLP, 10250 Constellation Boulevard, 19th

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Floor, Los Angeles, California 90067, [phone].
These individuals are the current chairman of the board or employees of

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LegalZoom and should not be contacted except through counsel for LegalZoom:

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Patricia L. Glaser and Fred D. Heather, Glaser Weil Fink Jacobs Howard Avchen &

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Shapiro LLP, 10250 Constellation Boulevard, 19th Floor, Los Angeles, California
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LEGALZOOM.COM, INC.’S AMENDED RULE 26(A)(1) DISCLOSURES
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90067, [phone]. The aforementioned individuals are knowledgeable and are

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expected to have information regarding LegalZoom’s marketing, advertisements and

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promotions as well as LegalZoom’s business operations.

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Dated: September 26, 2013

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Respectfully submitted,
By: /s/ Fred D. Heather
Patricia L. Glaser
[e-mail]
Fred D. Heather
[e-mail]
Mary Ann T. Nguyen
[e-mail]
GLASER WEIL FINK JACOBS
HOWARD AVCHEN &
SHAPIRO LLP
10250 Constellation Boulevard,
19th Floor
Los Angeles, California 90067
Tel.: [phone]
Fax.: [phone]

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Attorneys for Plaintiff
LEGALZOOM.COM, INC.

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LEGALZOOM.COM, INC.’S AMENDED RULE 26(A)(1) DISCLOSURES
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