LegalZoom.com Inc v. Rocket Lawyer Incorporated

Filing 83

DECLARATION of Hong-An Vu re Objection/Opposition (Motion related),, 82 , Notice of Manual Filing (G-92),, 81 IN OPPOSITION TO LEGALZOOM.COM, INC.'S MOTION FOR PARTIAL SUMMARY JUDGMENT filed by Defendant Rocket Lawyer Incorporated. (Attachments: # 1 EX 9-35)(Vu, Hong-An)

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EXHIBIT 9 -43-

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EXHIBIT 10

G l ase r __-~-_ i I ~•...._--~-.-~-._ ~ °~w~..~ bs
We Fink aco
°.~----Howard Avchen Shapiro ~~.P

10250 Constellation Blvd.
19th Floor
Los Angeles, CA 90067
310.553.3000 TEL
310.556.2920 FAX
Mary Ann T. Nguyen

December 18, 2013

VGA E-MAIL

Direct Dial
310.556.7809
Direct Fax
310.843.2609
Email
[e-mail]

Hong-An Vu, Esq.
Forrest A. Hainline, III, Esq.
GOODWIN PROCTER LLP
Three Embarcadero Center, 24th Floor
San Francisco, California 94111
Michael T. Jones, Esq.
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025-1105
RE:

LegalZoom.com, Inc. vs. Rocket Lawyer Incorporated -Proposed Custodians
and Search Terms

Dear Ms. Vu, et ol.:
We are in receipt of your November 25, 2013 letter regarding LegalZoom.com,
Inc.'s ("Le~alZoom") proposed custodians and search terms for Le~alZoom's
production in response to Rocket Lawyer tncorporated's ("Rocket Lawyer") Requests
for Production of Documents Set One and Set Two ("Rocket Lawyer's Requests for
Documents").
LegalZoom's Proposed Custodians and Search Terms
As a preliminary matter, based upon our examination of Rocket Lawyer's
Requests for Documents, we believe our proposed custodians and search terms are
adequate given the scope of the claims and defenses of the parties. However, to
further expedite the discovery process and to resolve our discovery issues outside the
Court, we are amenable to adding Chas Rampenthal, Patty Chikama~alur, Chyna
Smith, Frank Monestere, Jeremy Vernassal, and Peter Prucnel to LegalZoom's
custodians list.
In your letter, you inquired as to Le~alZoom's April 1, 2010 "cut-off" date.
Please be advised that LegalZoom converted to a new document management system
on or about April 1, 2010. As a result, LegalZoom's PST archives date back only to
April 1, 2010. LegalZoom's PST files dated prior to this date are largely inaccessible
and/or are accessible only with undue burden and cost to LegalZoom.
T.
Z MERITAS LAW FIRMS WORLDWIDE

841023.2

EXHIBIT 10-44-

Hong-An Vu, Esq.
Michael T. Jones, Esq.
December 18, 2013
Page 2

Rocket Lawyer's Proposed Custodians and Search Terms
In your letter, you indicated that Rocket Lawyer intends to reduce its custodian
list by removing Jared Colli, Rocket Lawyer's Product Marketing Manager, and Lisa
Honey, Rocket Lawyer's Business Lead. You contended that the removed individuals
are direct reports to managers already on Rocket Lawyer's custodian list and/or have
only been at Rocket Lawyer for a brief period of time, and that responsive documents
will be adequately captured in the collection, search and review of documents in
possession of managers included in Rocket Lawyer's custodian list. However,
LegalZoom does not agree to the removal of these custodians. Neither the fact that
they have been employed for a short period of time nor the fact that their managers
are already identified as custodians provides compelling justification for removing
them as possible custodians.
With regard to Rocket Lawyer's proposed search terms, while you contend that
Rocket Lawyer's proposed search terms are sufficient and that you "will continue to
investigate and test [LegalZoom's] proposed terms" and "will let [us] know whether
[you] are willing to add any [of LegalZoom's requested search terms]," LegalZoom
requests that you agree to add to Rocket Lawyer's existing list, the following terms,
which are likely to yield documents responsive to LegalZoom's First and Second Sets
of Requests for Production of Documents that you have indicated you will provide:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.

Zoom
Travis AND/OR Giggy
"Free LLC"
"Free incorporation"
"Pay no fees"
"$0 fees"
"Free help from local attorneys"
"Free legal review"
"On Call"
"Free Trial"
"Negative Option"
(Customer AND/OR Consumer) AND complaint*
(Federal Trade Commission AND/OR- FTC) AND complaint
(Better Business Bureau AND/OR BBB) AND complaint
(Customer AND/OR Consumer) AND confusion*
(Customer AND/OR Consumer) AND deception*
"Fees" or "State fees"
Advertis*
Pric*

841023.2

EXHIBIT 10-45-

Hong-An Vu, Esq.
Michael T. Jones, Esq.
December 18, 2013
Page 3

20.
21.
22.
23.
24.

"Terms of Service" AND (modify AND/OR change)
"On call terms of service"
Disclosure
Policy AND disclos*
Condition AND disclos*

LegalZoom reserves the right to request that additional search terms be added to
Rocket Lawyer's search terms list.
Although the holidays are upon us, we would like production on a rolling basis.
Please confirm that you will commence production no later than January 6, 2014.
We are willing to further meet and confer with you regarding these issues. Of
course, this letter is sent without waiver of any of LegalZoom's rights and remedies,
alt of which are expressly reserved.
Sincerely,

MARY ANN T. NGUYEN
for GLASER WEIL FINK JACOBS HOWARD AVCHEN ~ SHAPIRO LLP

MTN / mtn
cc: Fred Heather, Esq.
Patricia Jones Winograd, Esq.

841023.2

EXHIBIT 10-46-

EXHIBIT 11

EXHIBIT 11

Own Vision LLC Review - Business Consultants in Fort Collins, CO - BBB Business Review - BBB serving Northern Colorado and Wyoming

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4420 Kano Dr, Fort Collins, CO 80526
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EXHIBIT 11 -47http://www.bbb.org/wyoming-and-northern-colorado/business-reviews/business-consultants/own-vision-llc-in-fort-collins-co-46013488[10/10/2013 2:00:51 PM]

Own Vision LLC Review - Business Consultants in Fort Collins, CO - BBB Business Review - BBB serving Northern Colorado and Wyoming

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Additional Information
BBB file opened: February 28, 2008
Business started: 04/01/2004
Business started locally: 04/01/2004
Business incorporated: 01/01/2008 in CO

Type of Entity
Limited Liability Company (LLC)

Business Management
Mr. Travis Giggy, Owner
Ms. Monique Giggy, Co Owner

Contact Information
Principal: Mr. Travis Giggy, Owner

Business Category
Business Consultants
Copyright Services
Estate Planning & Management
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Internet Service Providers
Self Improvement Motivation Classes
Organizing Services
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Patent Agents
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EXHIBIT 11 -48http://www.bbb.org/wyoming-and-northern-colorado/business-reviews/business-consultants/own-vision-llc-in-fort-collins-co-46013488[10/10/2013 2:00:51 PM]

Own Vision LLC Review - Business Consultants in Fort Collins, CO - BBB Business Review - BBB serving Northern Colorado and Wyoming
Global Positioning Systems
Legal Form Suppliers
Business Form Suppliers
Attorneys Service Bureaus

Alternate Business Names
LegalSpring.com
Smallbusinessvictory.com

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EXHIBIT 11 -49http://www.bbb.org/wyoming-and-northern-colorado/business-reviews/business-consultants/own-vision-llc-in-fort-collins-co-46013488[10/10/2013 2:00:51 PM]

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EXHIBIT 34

PATRICIA L. GLASER -State Bar No. 55668
pglaser glaserweil.com
2 FRED .HEATHER -State Bar No. 110650
fheather~glaserweil.com
3 MARY NN T. NGUYEN —State Bar No. 269099
[e-mail]
4 GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP
5 10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
)
6 Telephone: [phone]
[phone]
Facsimile:
I

Attorneys for Rocket Lawyer
LegalZoom.com, Inc.
s
9

UNITED STATES DISTRICT COURT

~o

CENTRAL DISTRICT OF CALIFORNIA

ii

WESTERN DIVISION

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LEGALZOOM.COM,INC., a Delaware
corporation

Hon. Gary A. Feess

i4

t6

CASE NO.: CV 12-9942-GAF(AGRx)

Plaintiff,
v.

ROCKET LAWYER INCORPORATED,
1~ a Delaware corporation
Defendant.
ig

LEGALZOOM.COM,INC.'S
SUPPLEMENTAL RESPONSES TO
ROCKET LAWYER
INCORPORATED'S FIRST SET OF
SPECIAL INTERROGATORIES

19
20
21
22
23
24
25
26
27
28
LEGALZOOM.COM,INC.'S SUPPLEMENTAL RESPONSE TO ROCKET LAWYER INCORPORATED'S FIRST
SET OF SPECIAL INTERROGATORIES
EXHIBIT 34 -129-

relating to this action, and has not yet reviewed all materials relating to this action,
interviewed all witnesses in this action, and has not yet completed its preparation for
trial, LegalZoom reserves the right to amend and/or supplement its responses to these
Interrogatories if and when additional facts or documents are discovered.
Additionally, because LegalZoom responses are based on facts and documents that
LegalZoom has indentified to date, they do not preclude LegalZoom from later
relying on facts or documents discovered or generated pursuant to subsequent
investigation or discovery. LegalZoom's partial response to any Interrogatory is not
to be construed as a waiver of any of its rights to object to any other Interrogatory.
io
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SUPPLEMENTAL RESPONSES AND OBJECTIONS

ii INTERROGATORY NO.7:
12

Describe Your relationship with LegalSpring.com from 2004 to the present.

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RESPONSE TO INTERROGATORY NO.7:
LegalZoom incorporates by reference each of the foregoing General

~s Objections. LegalZoom objects to this Interrogatory to the extent it calls for
16 information protected by the attorney-client privilege, the work product doctrine, or

any other applicable exemption from discovery. LegalZoom further objects to this
is Interrogatory as calling for confidential and proprietary information. LegalZoom
i9 further objects to this Interrogatory on the grounds that this Interrogatory seeks
Zo information that is not relevant to this action or likely to lead to the discovery of
21

admissible evidence. LegalZoom further objects to the extent this Interrogatory seeks

22 information that is publicly available, and hence equally available to all parties to this
23

litigation, or not in LegalZoom's possession, custody, or control. LegalZoom further

24

objects to this Interrogatory as vague and ambiguous to the extent the phrase

zs "relationship" is not defined or understood. LegalZoom further objects to the
26

definition of "Your" as including LegalZoom's "past and present agents,

2~

representatives, and all persons now or previously under its control, and all persons

2s currently or previously acting or purporting to act on its behalf" This definition is
LEGALZOOM.COM,INC.'S SUPPLEMENTAL RESPONSE TO ROCKET LAWYER INCORPORATED'S FIRST
SET OF SPECIAL INTERROGATORIES
EXHIBIT 34 -130-

impermissibly vague, ambiguous, and overly broad, and renders any related requests
unduly burdensome, unreasonable, and oppressive. LegalZoom shall limit the term
"Your" to mean LegalZoom.com, Inc.
Subject to and without waiver of the foregoing general and specific objections,
LegalZoom responds as follows:
Based on the information and documents currently available to LegalZoom,
beginning in 2005, Legalspring.com acted as an affiliate of LegalZoom to generate
leads.
SUPPLEMENTAL RESPONSE TO INTERROGATORY N0.7
to

LegalZoom incorporates by reference each of the foregoing General

tl Objections. LegalZoom objects to this Interrogatory to the extent it calls for
~.
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~2 information protected by the attorney-client privilege, the work product doctrine, or
13

any other applicable exemption from discovery. LegalZoom further objects to this

i4 Interrogatory as calling for confidential and proprietary information. LegalZoom

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15

further objects to this Interrogatory on the grounds that this Interrogatory seeks

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information that is not relevant to this action or likely to lead to the discovery of

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i~ admissible evidence. LegalZoom further objects to the extent this Interrogatory seeks
ig information that is publicly available, and hence equally available to all parties to this
19

litigation, or not in LegalZoom's possession, custody, or control. LegalZoom further

Zo objects to this Interrogatory as vague and ambiguous to the extent the phrase
21

"relationship" is not defined or understood. LegalZoom further objects to the

zz definition of "Your" as including LegalZoom's "past and present agents,
23

representatives, and all persons now or previously under its control, and all persons

24

currently or previously acting or purporting to act on its behalf." This definition is

25

impermissibly vague, ambiguous, and overly broad, and renders any related requests

26

unduly burdensome, unreasonable, and oppressive. LegalZoom shall limit the term

2~

"Your" to mean LegalZoom.com,Inc.

2g

Subject to and without waiver of the foregoing general and specific objections,
LEGALZOOM.COM,INC.'S SUPPLEMENTAL RESPONSE TO ROCKET LAWYER INCORPORATED'S FIRST
SET OF SPECIAL INTERROGATORIES
EXHIBIT 34 -131-

LegalZoom responds as follows:
2

Based on the information and documents currently available to LegalZoom,

3

I beginning in 2005 and continuing at least until January, 2013, Legalspring.com acted

4

'~ as an affiliate of LegalZoom to generate leads. Legalspring.com also acted, on

5

occasion, as a conduit through which LegalZoom could respond to its customers'

6

reviews that were posted on Legalspring.com's website.
INTERROGATORY NO.8:

s

Describe all work performed by Legalspring.com for LegalZoom.

9 RESPONSE TO INTERROGATORY NO.8:
10

LegalZoom incorporates by reference each of the foregoing General

11
~„ ~

L..

Objections. LegalZoom objects to this Interrogatory to the extent it calls for

12

information protected by the attorney-client privilege, the work product doctrine, or

]3

any other applicable exemption from discovery. LegalZoom further objects to this

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~4 Interrogatory as calling for confidential and proprietary information. LegalZoom
is further objects to this Interrogatory on the grounds that this Interrogatory seeks

16
~~

information that is not relevant to this action or likely to lead to the discovery of
admissible evidence. LegalZoom further objects to the extent this Interrogatory seeks

ig information that is publicly available, and hence equally available to all parties to this
i9 litigation, or not in LegalZoom's possession, custody, or control. LegalZoom further
Zo objects to this Interrogatory as overly broad, unduly burdensome, and harassing as it
21

is not limited in either time or scope. LegalZoom further objects to this Interrogatory

22

as vague and ambiguous to the extent the phrase "work performed" is not defined or

23

understood. LegalZoom further objects to the definition of "Your" as including

24

LegalZoom's "past and present agents, representatives, and all persons now or

z,s previously under its control, and all persons currently or previously acting or
26

purporting to act on its behalf." This definition is impermissibly vague, ambiguous,

2~

and overly broad, and renders any related requests unduly burdensome, unreasonable,

2s and oppressive. LegalZoom shall limit the term "Your" to mean LegalZoom.com,
LEGALZOOM.COM,INC.'S SUPPLEMENTAL RESPONSE TO ROCKET LAWYER INCORPORATED'S FIRST
SET OF SPECIAL INTERROGATORIES
EXHIBIT 34 -132-

i Commission beginning May 10, 2012. LegalZoom further states: pursuant to the
a parties' continuing and ongoing meet and confer efforts, LegalZoom will provide
summary information relating to its financial performance from 2008 to the present
4

subject to the terms of the protective order in this case.

5

6 DATED: December 3, 2013

s

10

~t
i2

GLASER WEIL FINK JACOBS
HOWARD AVCHEN & SHAPIRO LLP

By:
PATRICIA L. GLAS R
FRED D. HEATHER
MARY ANN T. NGUYEN
Attorneys for Plaintiff
LegalZoom.com, Inc.

13
14
15
16
17
18
19
20
21
22
23
24
25 I
26
27
28
LEGALZOOM.COM,INC.'S SUPPLEMENTAL RESPONSE TO ROCKET LAWYER INCORPORATED'S FIRST
SET OF SPECIAL INTERROGATORIES
EXHIBIT 34 -133-

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