Overture Services, Inc. v. Google Inc.

Filing 113

Declaration in Support of 112 [Plaintiff Overture Services, Inc.'s Corrected Motion to Compel Production of Damages Documents] filed by Overture Services, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P# 17 Exhibit Q# 18 Exhibit R# 19 Exhibit S# 20 Exhibit T# 21 Exhibit U# 22 Exhibit V# 23 Exhibit W)(Related document(s) 112 ) (Byrnes, Andrew) (Filed on 1/29/2004)

Overture Services, Inc. v. Google Inc.

Doc. 113 Att. 19

Case 3:02-cv-01991-JSW

Document 113-20

Filed 01/29/2004

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Case 3:02-cv-01991-JSW
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Document 113-20
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Filed 01/29/2004

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Michael S. K m , Esq.

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Re

Overture v. Google
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Case 3:02-cv-01991-JSW

Document 113-20

Filed 01/29/2004

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KEx(ER & V N NEST A
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September 26,2002

VIA FACSIMILE

Jack C. Bcxenzweig, Esq. Brinks Hofer Gilson & Lione NBC Tower - Suite 3600 455 N. Cityfront Plaza Drive Chicago, I GO61 1 L

Re:.

Overtiire V R Googlc

Dear Jack Following up on our discussions about phasing discovery, we propose to phase damages discovery only. This would mean that we would defer production of documents responsive l o Overture's Request for ProductionNos. 26,31,32,3645 and 51-60. We would also defer topics 3,5,6,7 and 14 from Overture's Rule 30(b)(6) deposition notice. In addition, we propose to redact financial terms from documents such as partncr agreements. Finally, for any documents related to unannounced partner agreements (actual agreements and potential agreements), we propose to redact identiying information concerning the non-GoogIe parties.

T look forward to discussing this proposal with you.
Sincerely,
#

MSK& cc: Jon B. Streeter, Esq.

298903.01