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

Filing 104

Attachment 14
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)

Download PDF
Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 104 Att. 14 Case 5:03-cv-05340-JF Document 104-15 Filed 06/08/2006 Page 1 of 3 EXHIBIT N Dockets.Justia.com Case 5:03-cv-05340-JF Document 104-15 Filed 06/08/2006 Page 2 of 3 LAW OFFICES KEKER & VAN NEST LLP 710 SANSOME STREET SAN FRANCISCO, CA 94111-1704 , TELEPHONE (415) 391-5400 FAX (415) 397-7188 KLAUS H. HAMM KHAMM(iKVN.COM WWW.KVN.COM June 1,2006 VIA FACSIMILE AND U.S. MAIL David A. Rammelt Kelley Drye & Waren LLP 333 West Wacker Drive 26th Floor Chìcago,IL 60606 Facsimile: 312/857-7095 Re: Google Inc. v. American Blind & Wallpaper Factory, Inc. Dear David: and former American Blind employees. years and fact discovery closes in less than Although this case has been pending for two and half four weeks, Google has not yet been able to take any depositions. I write regarding the depositions of current letter to you enclosed deposition notices for Bill Smith, Jeff Alderman and the noticed dates are not convenient. Scot Powers. That letter requested that you notify me if assume that the dates are acceptable. My Because I have not received a response from you, I and inquired whether you May 19 letter also enclosed a deposition subpoena for Joe Chamo, would accept service of this subpoena. Because I have not heard from you, I assume that you will not accept service. Starting tomorrow, we wil attempt to serve Mr. Chamo. My May 19 With this letter, I enclose a deposition subpoena for Steve Katzman. Please advise me by 2 p.m PST tomorrow whether you will accept service of this subpoena. If I do not hear from you, we wil attempt to serve Mr. Katzman. American Blind's designee for the 30(b)(6) notice that Google served on February 15 and provide us with dates for when he or she will be available for deposition. Finally, please notify us who wil serve as Please feel free to contact me about any of the issues raised in this letter. Very truly yours, Klaus H. Hamm Enclosure cc: Carolyn Plater 1l1l1-& 374210.01 Case 5:03-cv-05340-JF AO 88 (Rev. 11194) Subpoena in a Civil Case Document 104-15 Filed 06/08/2006 Page 3 of 3 Issued by the UNITED STATES DISTRICT COURT EAsTERN DISTRICT OF MJ;CHIGAN GOOGLE, INC. SUBPOENA IN A CIVIL CASE v. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratet.oday. com, Inc., and DOES 1- Case Number: i C 03 - 5340 - JF (EAI ) 100, inclusive Northern District of California San Jose Division TO: Steve Katzman c/o David Rammelt, Kelley Drye & Warren LLP; 333 West Wacker Drive, Suite 2600, Chicago, IL 60606 YOU ARE COMMANDED to appear in the United States District Cour at the place, date, and time specified below to PLACE OF TESTIMONY COURTROOM DATE AND TIME testify in the above case. x ' YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the takg of a deposition in PLACE OF DEPOSITION DATE AND TIME be the a ove soun -an -yisua means, inc by1stenographic an in erac will rea t' recorded case. b d d . 1 . u in d'eota d means and t' also ime. yi . e d . t iye 1 b The deposition will be recorded Detroit, MI 48243 9:30 a.m. PLACE Pepper Hamilton, LLP, 100 Renaissance Center, #3600, June 23, 2006 YOU ARE COMMANDED to produce and permt inspection and copying of the following documents or objects at the place, date, and time specified below (list documents or objects): I DATEANOTIME 'REMISES I OATEANOTI.E the matters on which the person wil testify. Federal Rules of Civil Procedure, 30(b)(6). ISSUING OFnE ~GN~tE ~~LE (INDICATE IF : YOU ARE COMMANDED to permt inpection of the following premises at the date and tie specified below. Any organization not a part to this suit that is subpoenaed for the taking of a deposition shall designate one or more offcers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, ATTORNEY FOR PLAINTIFF OR DEFENDANT) DATE Klaus J. Hamm Attorne for Plaintiff GOGGLE INC . June 1 2006 ISSUING OFFICER'S NAME ADDRESS AND TELEPHONE NUMBER Keker & Van Nest, LLP, 710 Sansome Street, San Francisco, CA 94111 Tel: (415) 391-5400 (See Rule 45, Federal Rules orCivil Predure, part C & D on reverse) 'Ifaction is ¡Jendin~ in distrct other than distrct of issuance, state distrct under case number. AO-SS

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?