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

Filing 144

Declaration of CAROLINE C. PLATER IN SUPPORT OF AMERICAN BLIND AND WALLPAPER FACTORY, INC.'S MOTION TO COMPEL GOOGLE TO RESPOND TO DISCOVERY TIMELY SERVED GIVEN THE CURRENT CUTOFF DATE OF AUGUST 26, 2006 filed byAmerican Blind & Wallpaper Factory, 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)(Andelman, Ethan) (Filed on 7/13/2006)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 144 Case 5:03-cv-05340-JF Document 144 Filed 07/13/2006 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 Robert N. Phillips (SBN 120970) Ethan B. Andelman (SBN 209101) HOWREY LLP 525 Market Street, Suite 3600 San Francisco, CA 94105 Telephone: (415) 848-4900 Facsimile: (415) 848-4999 David A. Rammelt (Admitted Pro Hac Vice) Susan J. Greenspon (Admitted Pro Hac Vice) Dawn M. Beery (Admitted Pro Hac Vice) KELLEY DRYE & WARREN LLP 333 West Wacker Drive, Suite 2600 Chicago, IL 60606 Telephone: (312) 857-7070 Facsimile: (312) 857-7095 Attorneys for Defendant/Counter-Plaintiff AMERICAN BLIND AND WALLPAPER FACTORY, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA GOOGLE INC., a Delaware corporation, Plaintiff, v. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc.; and DOES 1100, inclusive, Defendants. Case No. C 03-5340-JF (RS) DECLARATION OF CAROLINE C. PLATER IN SUPPORT OF AMERICAN BLIND AND WALLPAPER FACTORY INC.'S MOTION TO COMPEL GOOGLE TO RESPOND TO DISCOVERY TIMELY SERVED GIVEN THE CURRENT CUTOFF DATE OF AUGUST 26, 2006 Date: TBD Time: TBD Courtroom: 4 Hon. Richard Seeborg AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc., Counter-Plaintiff, v. GOOGLE, INC., Counter-Defendants CASE NO.: C03-5340-JF(RS DECLARATION OF CAROLINE C. PLATER IN SUPPORT OF MOTION TO COMPEL) DM_US\8366098.v1 Dockets.Justia.com Case 5:03-cv-05340-JF Document 144 Filed 07/13/2006 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 I, Caroline C. Plater declare as follows: 1. I am an attorney at Kelley Drye & Warren LLP, counsel of record for Defendant/Counter-Plaintiff American Blind and Wallpaper Factory, Inc. ("American Blind") in the above-captioned action. I am a member in good standing of the State Bar of Illinois. I have personal knowledge of the facts set forth in this declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Attached hereto as Exhibit A is a true and correct copy of the Transcript of Proceedings Before the Honorable Jeremy Fogel, dated June 23, 2006. 3. Attached hereto as Exhibit B is a true and correct copy of American Blind and Wallpaper Factory Inc.'s First Set of Requests For Admission to Google Inc. 4. Larry Page. 5. Sergey Brin. 6. Attached hereto as Exhibit E is a true and correct copy of correspondence from Attached hereto as Exhibit D is a true and correct copy of Notice of Deposition of Attached hereto as Exhibit C is a true and correct copy of Notice of Deposition of Klaus H. Hamm to Caroline C. Plater, dated June 26, 2006. 7. Attached hereto as Exhibit F is a true and correct copy of correspondence from Klaus H. Hamm to Caroline C. Plater, dated June 28, 2006. 8. Attached hereto as Exhibit G is a true and correct copy of correspondence from David A. Rammelt to Klaus H. Hamm, dated June 30, 2006. 9. Attached hereto as Exhibit H is a true and correct copy of e-mail correspondence between David A. Rammelt and Michael Page, dated July 2, 2006. 10. Attached hereto as Exhibit I is a true and correct copy of correspondence from Caroline C. Plater to Klaus H. Hamm, dated July 11, 2006. 11. Attached hereto as Exhibit J is a true and correct copy of e-mail correspondence from Michael Page copying David A. Rammelt, dated July 11, 2006. 12. Attached hereto as Exhibit K is a true and correct copy of American Blind and Wallpaper Factory Inc.'s Initial Disclosures Pursuant to Fed. R. Civ. P. 26. CASE NO.: C03-5340-JF(RS DECLARATION OF CAROLINE C. PLATER IN SUPPORT OF MOTION TO COMPEL) DM_US\8366098.v1 -2- Case 5:03-cv-05340-JF Document 144 Filed 07/13/2006 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 KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606 13. Attached hereto as Exhibit L is a true and correct copy of excerpts from the deposition of Alana Karen, taken in this case on April 12, 2006. 14. Attached hereto as Exhibit M is a true and correct copy of excerpts from the deposition of Prashant Fuloria, taken in this case on May 18, 2006. I declare under penalty of perjury that the foregoing is true and correct. Executed this 13th day of July 2006, in Chicago, Illinois. __/s/ Caroline C. Plater___________ CAROLINE C. PLATER CASE NO.: C03-5340-JF(RS DECLARATION OF CAROLINE C. PLATER IN SUPPORT OF MOTION TO COMPEL) DM_US\8366098.v1 -3-

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