Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 104

Attachment 12
Declaration in Support of 102 MOTION to Compel ABWF to (1) Produce Documents, (2) Produce an Affidavit, and (3) Schedule Depositions filed byGoogle Inc., Google 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)(Related document(s)102) (Krishnan, Ajay) (Filed on 6/8/2006)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 104 Att. 12 Case 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Page 1 of 6 EXHIBIT L Dockets.Justia.com Message Case 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Page 2 Page i of5 of 6 Robert Thomas '_o/u"""""",,,,,,,,,~__-,_,_,-,o/_=_=,~=,,.,..~~v~'--..n_---'.-m_-_~___~"'r"'N~"'-''-''-'_'__,~'':Wo/''_='W='''''''''-~''.'''.''''~~''''''''''_'',,""_~~'i~~~=~ From: Ajay Krishnan Sent: Thursday, June 08, 2006 2:40 PM To: Robert Thomas Subject: FW: Extension of time to respond to Google's letter re document requests -----Original Message----From: Plater, Caroline C. (mailto:CPlater(gKelleyDrye.com) Sent: Thursday, March 30, 2006 12:50 PM To: Ajay Krishnan Cc: Greenspon, Susan Subject: RE: Extension of time to respond to Google's letter re document requests Ajay - that is agreed. Thank you for your cooperation. Carrie -----Original Message----From: Ajay Krishnan (mailto:AKrishnan(gkvn.com). Sent: Thursday, March 30, 2006 1:19 PM To: Plater, Caroline C. Cc: Greenspon, Susan Subject: RE: Extension of time to respond to Google's letter re document requests Carrie -- May 11th for the 30(b)(6) depo works for us. I'LL expect a response to my letter from 3/28 on 4/10. Agreed? Thanks, Ajay -----Original Message----From: Plater, Caroline C. (mailto:CPlater(gKelleyDrye.com) Sent: Thursday, March 30, 2006 10:20 AM To: Ajay Krishnan Cc: Greenspon, Susan Subject: RE: Extension of time to respond to Google's letter re document requests Ajay - We have May 11th open. Unfortunately, both our client and attys are pretty solidly booked in these two weeks. If this date does not work for Google, I wil go into the following weeks for more dates. Please let me know how you would like to proceed. Thanks, Carrie -----Original Message----From: Ajay Krishnan (mailto:AKrishnan(gkvn.com) Sent: Wednesday, March 29, 20066:15 PM To: Plater, Caroline C. Subject: RE: Extension of time to respond to Google's letter re document requests Great. Thanks. -----Original Message----From: Plater, Caroline C. (mailto:CPlater(gKelleyDrye.com) Sent: Wednesday, March 29, 20064:14 PM To: Ajay Krishnan Subject: RE: Extension of time to respond to Google's letter re document requests 6/8/2006 Message Case 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Page 3 Page 2 of5 of 6 Ajay, I appreciate the prior diffculties in scheduling. We will set a new date. I just have to get a hold of our client. I hope to do that within the you with the potential dates as soon as I speak to next day. I wil provide him. Thanks, Carrie -----Original Message----From: Ajay Krishnan (mailto:AKrishnan(gkvn.com) Sent: Wednesday, March 29, 2006 6:06 PM To: Plater, Caroline C. Subject: RE: Extension of time to respond to Google's letter re document requests Thanks, Carrie. i just wanted to clarify that my agreementto the one-week extension was contingent on actually setting on a new 30(b)(6) deposition date (as you might recall, arriving at the April 20th date was not a trivial process). I am confident, though, that if you provide a reasonable number of options in those first two weeks of May, we will be able to work this out. For the present, however, since we have not yet reached agreement, we are stil on a fairly tight timeline. Do you know when you will be able to get back to me with potential dates? Thanks, Ajay -----Original Message----From: Plater, Caroline C. (mailto: CPlater(gKelleyDrye.com) Sent: Wednesday, March 29, 2006 3:38 PM To: Ajay Krishnan Subject: RE: Extension of time to respond to Google's letter re document requests Ajay -- Thank you for the accommodation. We agree to reschedule Google's30(b)(6) deposition of ABWF and agree to try to provide mutually convenient dates in the first two weeks of May. Once we have ascertained our client's availability during that time, i will transmit the potential dates to you. Your cooperation is appreciated. Regards, Carrie Plater -----Original Message----From: Ajay Krishnan (mailto:AKrishnan(9kvn .com) Sent: Wednesday, March 29, 2006 5:27 PM To: Plater, Caroline C. "of time to respond to Subject: Extension Google's letter re document requests Dear Caroline, letter from this morning concerning Google's discovery disputes. Although I would normally agree to the Thank you for your 6/812006 Message Case 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Page 4 Page 3 of5 of 6 extension you proposed, I need to ensure that Google obtains the many categories of documents mentioned in my lettér from yesterday before Google's 30(b)(6) deposition of ABWF. I would therefore agree to push back ABWF's time to respond so long as you can provide a later date that is convenient for Google's attorneys at which ABWF's representative will be available for a 30(b)(6) deposition. Based on our last round of deposition scheduling, there were no mutually agreeable dates in ApriL. .If you can provide a date in the first two weeks of May that is for a 30(b) convenient for Google's attorneys (6) deposition, I wil agree to the one week extension you proposed. Sincerely, Ajay Krishnan Ajay S. Krishnan Keker & Van Nest LLP 710 Sansome Street San Francisco, CA 94111 (415) 391-5400 akrishnan~kvn.com This message is intended only for the use of the individual or entity to whom it is addressed. The message is confidential and may contain attorney-client information, attorney work product or other privileged information. If you are not the intended recipient, you are hereby notified that any use or dissemination of this message is strictly prohibited. If you received this message in error, please notify the sender by replying to the message. When complete, please delete the original message. Thank you. . Pursuant to Treasury Regulations, any U.S. federal tax advice contained in this communication, uness otherwise stated, is not intended and canot be used for the purose of avoiding tax-related penalties. The information contained in this E-mail i:essage is privileged, confidential, and may be 6/812006 Message Case 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Pa 6 Page 5 of ge 4 of5 protected from disclosure; please be aware that any other use, printing, copying, disclosure or dissemination of this communication may be you subject to legal restriction or sanction. If think that you have received this E-mail message in error, please reply to the sender. This E-mail message and any attachments have been scanned for viruses and are believed to be free of any virus or other defect that might into which it is affect any computer system received and opened. However, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Kelley Drye & Warren LLP for any loss or damage arising in any way from its use. Pursuant to Treasur Regulations, any U.S. federal tax advice contained in this communication, unless otherwise stated, is not intended and canot be used for the purpose of avoiding taxrelated penalties. The information contained in this E-mail message is privileged, confidential, and may be protected from disclosure; please be aware that any other use, printing, copying, disclosure or this communication may be subject to legal dissemination of restriction or sanction. If you think that you have received this Email message in error, please reply to the sender. This E-mail message and any attachments have been scaned for viruses and are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened. However, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Kelley Drye & Waren LLP for any loss or damage arising in any way from its use. 6/812006 MessageCase 5:03-cv-05340-JF Document 104-13 Filed 06/08/2006 Pg Page 6 ofa6e 5 of5 Pursuant to Treasur Regulations, any U.S. federal tax advice contained in this communication, unless otherwise stated, is not intended and cannot be used for the purose of avoiding tax-related penalties. The information contained in this E-mail message is privileged, confidential, and may be protected from disclosure; please be aware that any other use, printing, copying, disclosure or dissemination of this communication may be subject to legal restriction or sanction. If you think that you have received this E-mail message in error, please reply to the sender. This E-mail message and any attachments have been scaned for viruses and are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened. However, it is the responsibilty ofthe recipient to ensure that it is virus free and no responsibility is accepted by Kelley Drye & Warren LLP for any loss or damage arising in any way from its use. Pursuant to Treasur Regulations, any U.S. federal tax advice contained in this communication, unless otherwse stated, is not intended and cannot be used for the purpose of avoiding tax-related penalties. The information contained in this E-mail message is privileged, confidential, and may be protected from disclosure; please be aware that any other use, printing, copying, disclosure or dissemination of this communication may be subject to legal restriction or sanction. If you think that you have received this E-mail message in error, please reply to the sender. This E-mail message and any attachments have been scaned for viruses and are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened. However, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Kelley Drye & Warren LLP for any loss or damage arising in any way from its use. 6/8/2006

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