Netflix, Inc. v. Blockbuster, Inc.

Filing 79

Declaration of EUGENE M. PAIGE in Support of 78 MOTION to Compel Plaintiff Netflix, Inc.'s Notice of Motion and Memorandum of Points and Authorities in Support of its Motion to Compel the Production of Documents from Blockbuster, Inc. Declaration of Eugene M. Paige in Support of Netflix's Motion to Compel filed byNetflix, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B.1# 3 Exhibit B.2# 4 Exhibit B.3# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E# 8 Exhibit F)(Related document(s)78) (Chanin, Jeffrey) (Filed on 11/3/2006)

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Netflix, Inc. v. Blockbuster, Inc. Doc. 79 Case 3:06-cv-02361-WHA Document 79 Filed 11/03/2006 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 Date: Time: Judge: December 8, 2006 9:30 a.m. Hon. Joseph C. Spero April 4, 2006 Complaint filed: DECLARATION OF EUGENE M. PAIGE ISO NETFLIX'S MOTION TO COMPEL CASE NO. C 06 2361 WHA (JCS) Dockets.Justia.com Case 3:06-cv-02361-WHA Document 79 Filed 11/03/2006 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 I, EUGENE M. PAIGE, declare and state as follows: 1. I am an attorney duly licensed to practice before this Court, and am associated with Keker & Van Nest, LLP, counsel to Plaintiff and Counterclaim-Defendant Netflix, Inc. ("Netflix"). 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. On August 31, 2006, Netflix served its First Set of Requests for the Production of Documents on Defendant and Counterclaim-Plaintiff Blockbuster, Inc. ("Blockbuster"). A true and correct copy of those Requests is attached hereto as Exhibit A. 3. On October 2, 2006, Blockbuster served its Responses and Objections to Netflix's First Set of Requests for the Production of Documents. A true and correct copy of those Responses and Objections is attached hereto as Exhibit B. 4. Netflix sent a letter to Blockbuster on October 9, 2006, asking Blockbuster to remedy certain deficiencies in its Responses and Objections. A true and correct copy of the letter is attached hereto as Exhibit C. 5. On October 13, 2006, the parties personally met and conferred in San Francisco regarding the deficiencies in Blockbuster's Responses and Objections. Although some issues were resolved then and subsequent to then, the parties could not come to an agreement on all issues.. 6. On October 25, 2006, Netflix sent a letter to Blockbuster memorializing the parties' telephonic meet-and-confer session that took place on that date. A true and correct copy of that letter is attached hereto as Exhibit D. 7. On October 26, 2006, Netflix sent a letter to Blockbuster, memorializing the parties' telephonic meet-and-confer session that took place on that date. A true and correct copy of that letter is attached hereto as Exhibit E. 8. The parties outlined the discovery issues that remain in contention in a joint letter executed on November 2, 2006. A true and correct copy of that letter is attached hereto as Exhibit F. // 1 DECLARATION OF EUGENE M. PAIGE ISO NETFLIX'S MOTION TO COMPEL CASE NO. C 06 2361 WHA (JCS) Case 3:06-cv-02361-WHA Document 79 Filed 11/03/2006 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 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 November, 2006, at San Francisco, California. _________/s/ Eugene M. Paige__________ EUGENE M. PAIGE 2 DECLARATION OF EUGENE M. PAIGE ISO NETFLIX'S MOTION TO COMPEL CASE NO. C 06 2361 WHA (JCS)

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