Overture Services, Inc. v. Google Inc.

Filing 79

STIPULATION -- Joint Motion for Entry of Supplemental Stipulated Protective Order re Email by Overture Services, Inc.. (Attachments: # 1 Proposed Order -- Proposed Supplemental Stipulated Protective Order re Email)(McMahon, Charles)

Overture Services, Inc. v. Google Inc.

Doc. 79

Case 3:02-cv-01991-JSW

Document 79

Filed 08/11/2003

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LATHAM & WATKINS Anthony I. Fenwick (Bar No. 158667) 135 Commonwealth Drive Menlo Park, California 94025 Telephone: [phone] Facsimile: [phone] BRINKS HOFER GILSON & LIONE Jack C. Berenzweig (Admitted Pro Hac Vice) William H. Frankel (Admitted Pro Hac Vice) Jason S. White (Admitted Pro Hac Vice) Charles M. McMahon (Admitted Pro Hac Vice) NBC Tower - Suite 3600 455 North Cityfront Plaza Drive Chicago, Illinois 60611 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff OVERTURE SERVICES, INC. KEKER & VAN NEST, LLP John W. Keker (Bar No. 49092) Daralyn J. Durie (Bar No. 169825) Michael S. Kwun (Bar No. 198945) 710 Sansome Street San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant GOOGLE TECHNOLOGY INC., sued under its former name GOOGLE INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
OVERTURE SERVICES, INC., a Delaware Corporation, Plaintiff, vs. GOOGLE INC., a California Corporation, Defendant. No. C02-01991 JSW (EDL) JOINT MOTION FOR ENTRY OF STIPULATED SUPPLEMENTAL PROTECTIVE ORDER RE EMAIL DISCOVERY MATTER

Dockets.Justia.com

Case 3:02-cv-01991-JSW

Document 79

Filed 08/11/2003

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Plaintiff Overture Services, Inc. ("Overture") and defendant Google Technology, Inc. ("Google") jointly move pursuant to Rule 26(c)(7) of the Federal Rules of Civil Procedure for entry of a supplemental protective order regarding email. The proposed order, to which the parties stipulate, is attached hereto as an exhibit. In light of the volume of email currently used in the normal course of business, and in light of the conventions for electronic storage of such email, the parties recognize and agree that the process of identifying and reviewing email for potential production in response to document requests presents special burdens. Accordingly, the parties agree to adopt and follow the protocol set forth in the attached proposed order governing responses to document requests seeking email in this case.

Dated: August 11, 2003 By:

BRINKS HOFER GILSON & LIONE s/ Charles M. McMahon Charles M. McMahon Attorneys for Plaintiff OVERTURE SERVICES, INC. KEKER & VAN NEST, LLP By: s/ Michael S. Kwun Michael S. Kwun Attorneys for Defendant GOOGLE TECHNOLOGY, INC., sued under its former name GOOGLE, INC.

Dated: August 11, 2003

DECLARATION OF CHARLES M. MCMAHON I, Charles M. McMahon, declare that prior to filing the above Joint Motion for Entry of Stipulated Supplemental Protective Order re Email, I sent it to Michael S. Kwun for his review, and he authorized me to file the Joint Motion on his behalf. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on this 11th day of August 2003 at Chicago, Illinois. s/ Charles M. McMahon Charles M. McMahon
JOINT MOTION FOR ENTRY OF SUPPLEMENTAL PROTECTIVE ORDER RE EMAIL C 02-01991 JSW (EDL)

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