Netflix, Inc. v. Blockbuster, Inc.

Filing 155

Declaration Of Eugene M. Paige In Support Of Netflix's Motion To Compel The Production Of Documents From Blockbuster, Inc. filed byNetflix, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B1# 3 Exhibit B2# 4 Exhibit B3# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E# 8 Exhibit F# 9 Exhibit G# 10 Exhibit H# 11 Exhibit I# 12 Exhibit J# 13 Exhibit K# 14 Exhibit L# 15 Exhibit M)(Paige, Eugene) (Filed on 3/2/2007)

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Netflix, Inc. v. Blockbuster, Inc. Doc. 155 Case 3:06-cv-02361-WHA Document 155 Filed 03/02/2007 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KEKER & VAN NEST, LLP JEFFREY R. CHANIN - #103649 DARALYN J. DURIE - #169825 ASHOK RAMANI - #200020 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Plaintiff NETFLIX, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA NETFLIX, INC., a Delaware corporation, Plaintiff, v. BLOCKBUSTER, INC., a Delaware corporation, DOES 1-50, Defendant. Case No. C 06 2361 WHA (JCS) DECLARATION OF EUGENE M. PAIGE IN SUPPORT OF NETFLIX'S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS FROM BLOCKBUSTER, INC. Date: April 6, 2007 Time: 9:30 a.m. Judge: Hon. Joseph C. Spero Complaint filed: April 4, 2006 DECLARATION OF EUGENE M. PAIGE IN SUPPORT OF NETFLIX'S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS FROM BLOCKBUSTER, INC. CASE NO. C 06 2361 WHA (JCS) Dockets.Justia.com Case 3:06-cv-02361-WHA Document 155 Filed 03/02/2007 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 390981.01 I, EUGENE M. PAIGE, declare and state as follows: 1. I am an attorney duly licensed to practice in the State of California and before this Court, and am associated with Keker & Van Nest, LLP, counsel to Plaintiff and CounterclaimDefendant Netflix, Inc. I have personal knowledge of the facts set forth below, and if called to testify as a witness thereto could do so competently under oath. 2. Attached hereto as Exhibit A is a true and correct copy of Netflix's First Set of Requests for the Production of Documents to Blockbuster, served August 31, 2006. 3. Attached hereto as Exhibit B is a true and correct copy of Blockbuster, Inc.'s Response to Netflix's First Set of Requests for the Production of Documents to Blockbuster, served October 2, 2006. 4. Attached hereto as Exhibit C is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated December 6, 2006. 5. Attached hereto as Exhibit D is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated December 20, 2006. 6. Attached hereto as Exhibit E is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated January 2, 2007. 7. Attached hereto as Exhibit F is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated January 18, 2007. 8. Attached hereto as Exhibit G is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated February 6, 2007. 9. Attached hereto as Exhibit H is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated February 13, 2007. 10. Attached hereto as Exhibit I is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated February 16, 2007. 11. On February 21, 2007, Daralyn J. Durie and I, as counsel for Netflix, traveled to Los Angeles to conduct an in-person meet-and-confer with William J. O'Brien, counsel for Blockbuster. 12. Attached hereto as Exhibit J is a true and correct copy of a letter from William 1 DECLARATION OF EUGENE PAIGE IN SUPPORT OF NETFLIX'S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS FROM BLOCKBUSTER, INC. CASE NO. C 06 2361 WHA (JCS) Case 3:06-cv-02361-WHA Document 155 Filed 03/02/2007 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 O'Brien, counsel for Blockbuster, to me, dated February 23, 2007. 13. Attached hereto as Exhibit K is a true and correct copy of a letter from me to William O'Brien, counsel for Blockbuster, dated February 26, 2007. 14. Attached hereto as Exhibit L is a true and correct copy of a letter from William O'Brien, counsel for Blockbuster, to me, dated February 26, 2007. 15. Attached hereto as Exhibit M is a true and correct copy of a joint letter from William O'Brien and myself to the Honorable Joseph C. Spero, dated March 2, 2007. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this 2nd day of March 2007, at San Francisco, California. /s/ Eugene M. Paige ____________________ 2 390981.01 DECLARATION OF EUGENE PAIGE IN SUPPORT OF NETFLIX'S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS FROM BLOCKBUSTER, INC. CASE NO. C 06 2361 WHA (JCS)

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