LegalZoom.com Inc v. Rocket Lawyer Incorporated
Filing
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ROCKET LAWYER INCORPORATED'S REDACTED OPPOSITION TO re: MOTION for Partial Summary Judgment 69 filed by Defendant Rocket Lawyer Incorporated. (Attachments: # 1 ROCKET LAWYER INCORPORATED'S REDACTED STATEMENT OF GENUINE ISSUES IN SUPPORT OF OPPOSITION TO LEGALZOOM.COM, INC.'S MOTION FOR PARTIAL SUMMARY JUDGMENT, # 2 ROCKET LAWYER INCORPORATED'S MEMORANDUM OF EVIDENTIARY OBJECTIONS IN OPPOSITION TO LEGALZOOM'S MOTION FOR PARTIAL SUMMARY JUDGMENT)(Jones, Michael)
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Forrest A. Hainline III (SBN 64166)
fhainline@goodwinprocter.com
Hong-An Vu (SBN 266268)
hvu@goodwinprocter.com
GOODWIN PROCTER LLP
Three Embarcadero Center
24th Floor
San Francisco, California 94111
Tel.: 415.733.6000
Fax.: 415.677.9041
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
Brian W. Cook (Pro Hac Vice)
bcook@goodwinprocter.com
GOODWIN PROCTER LLP
53 State Street
Boston, MA 02109-2802
Tel.: 617.570.1000
Fax.: 617.523.1231
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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ACTIVE/74718449.1
Case No. 2:12-cv-09942-GAF-AGR
ROCKET LAWYER
INCORPORATED’S
MEMORANDUM OF
EVIDENTIARY OBJECTIONS IN
OPPOSITION TO LEGALZOOM’S
MOTION FOR PARTIAL
SUMMARY JUDGMENT
Date:
Time:
Judge:
Courtroom:
Action Filed:
August 18, 2014
9:30 a.m.
Judge Gary A. Feess
740
November 20, 2012
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Pursuant to the Court’s current standing Scheduling Order, Defendant Rocket
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Lawyer Incorporated (“Rocket Lawyer”) submits this Memorandum of Evidentiary
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Objections to Plaintiff Legalzoom.com, Inc.’s Separate Statement of Undisputed
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Material Facts.
Separate Statement Paragraph 4: Objection to Paragraph 4 of the Declaration
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of Dorian Quispe (“Quispe Decl.”) (“LegalZoom has not authored any of the
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reviews on Legalspring.com, and has no responsibility for the reviews which are
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actually posted.”) on the grounds that it is misleading. To the extent this statement
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implies that LegalZoom had no involvement in selecting the reviews that were
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posted on or removed from Legalspring.com, it is misleading. Fed. R. Evid. 403.
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Objection to Paragraph 4 of the Declaration of Travis Giggy (“Giggy Decl.”)
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(“Between 2004 and March 1, 2013, I selected and published on the
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Legalspring.com website opinions as well as third party customer reviews about
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various online legal service providers, including LegalZoom.”) on the grounds that
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it is misleading. To the extent this statement implies that Giggy acted alone in
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selecting customer reviews for publication, it is misleading. Fed. R. Evid. 403.
Separate Statement Paragraph 5: Same objection to Paragraph 4 of the Quispe
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Decl. as identified with respect to Separate Statement Paragraph 4, above.
Separate Statement Paragraph 6: Objection to Paragraph 3 of the Quispe Decl.
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(“The relationship between Legalspring.com and LegalZoom is, and always has
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been, that of affiliate and client.”) on the grounds that it is misleading. To the extent
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it is offered to show that the current relationship between LegalZoom and
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Legalspring.com is the same as it always has been, it is misleading. Fed. R. Evid.
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403.
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Separate Statement Paragraph 8: Objection to Paragraph 6 of the Quispe Decl.
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(“While Mr. Giggy, at one time, received compensation from LegalZoom for any
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products sold by LegalZoom as a result of a consumer first visiting
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Legalspring.com, that relationship terminated as of March 2013.”) and Paragraph 8
ACTIVE/74718449.1
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of the Giggy Decl. (“Like other affiliate referral sites, Legalspring.com received
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commissions and/or compensation from its affiliates, including from LegalZoom.”)
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on the grounds that the evidence is incomplete and misleading. To the extent these
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statements imply that this is the only form of compensation paid by LegalZoom to
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Mr. Giggy with respect to Legalspring.com, it is incomplete and misleading. Fed.
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R. Evid. 106, 403.
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Separate Statement Paragraph 10: Objection to Paragraph 8 of the Quispe
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Decl. (“”) and Paragraph 9, Exhibit B, of the Giggy Decl. on the grounds that they
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are misleading. To the extent the evidence is offered to show that this is the only
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content on Legalspring.com that was authored by LegalZoom, it is incomplete and
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misleading. Fed. R. Evid. 106, 403.
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Dated: July 28, 2014
GOODWIN PROCTER LLP
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By: /s/ Michael T. Jones
Forrest A. Hainline III (SBN 64166)
fhainline@goodwinprocter.com
Hong-An Vu (SBN 266268)
hvu@goodwinprocter.com
Michael T. Jones (SBN 290660)
mjones@goodwinprocter.com
Brian W. Cook (Pro Hac Vice)
bcook@goodwinprocter.com
GOODWIN PROCTER LLP
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Attorneys for Defendant
ROCKET LAWYER INCORPORATED
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ACTIVE/74718449.1
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