Google Inc. v. American Blind & Wallpaper Factory, Inc.
Filing
64
Declaration of Caroline C. Plater in Support of
63 MOTION for Discovery
Defendant's Notice of Motion and Motion to Enforce Stipulated Protective Order and to Dedesignate Documents filed byAmerican Blind & Wallpaper Factory, Inc.. (Attachments: #
1 Exhibit A#
2 Exhibit B-G: Copy of Notice of Manual Filing#
3 Exhibit H#
4 Exhibit I#
5 Exhibit J#
6 Exhibit K)(Related document(s)
63) (Andelman, Ethan) (Filed on 12/23/2005)
Google Inc. v. American Blind & Wallpaper Factory, Inc.
Doc. 64
Case 5:03-cv-05340-JF
Document 64
Filed 12/23/2005
Page 1 of 3
KELLEY DRYE & WARREN LLP 333 WEST W
Dockets.Justia.com
Case 5:03-cv-05340-JF
Document 64
Filed 12/23/2005
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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 & 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 Stipulated
Protective Order entered in this action. 3. Attached hereto as Exhibit B are true and correct copies of documents
produced by Plaintiff/Counter-Defendant Google, Inc. ("Google"), with Bates Nos. GOOGLE 19971-19996. 4. Attached hereto as Exhibit C are true and correct copies of documents
produced by Google with Bates Nos. GOOGLE 008990-008993. 5. Attached hereto as Exhibit D are true and correct copies of documents
produced by Google with Bates Nos. GGE 005313-005314, 005443-005444, 005468-005469, 005531-005533, 005535-005537, 005549-005551, 005571-005572, 005579-005580, 005585005587, 005606-005607, 005670-005671. 6. Attached hereto as Exhibit E are true and correct copies of documents
produced by Google with Bates Nos. GOOGLE 002717-002723. 7. Attached hereto as Exhibit F is a true and correct copy of correspondence
from David A. Rammelt to Klaus Hamm, dated November 3, 2005. 8. Attached hereto as Exhibit G is a true and correct copy of correspondence
from Klaus Hamm to David A. Rammelt, dated November 8, 2005. 9. Attached hereto as Exhibit H is a true and correct copy of correspondence
from David A. Rammelt to Klaus Hamm, dated November 22, 2005. 10. Attached hereto as Exhibit I is a true and correct copy of an e-mail from
David A. Rammelt to Klaus Hamm, dated November 29, 2005.
Case No. C03-5340 JF Declaration of Caroline C. Plater ISO Motion to Enforce Stipulated Protective Order DM_US\8294100.v1
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Case 5:03-cv-05340-JF
Document 64
Filed 12/23/2005
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KELLEY DRYE & WARREN LLP 333 WEST WACKER DRIVE SUITE 2600 CHICAGO, IL 60606
11.
Attached hereto as Exhibit J is a true and correct copy of correspondence
from Klaus Hamm to David A. Rammelt, dated November 29, 2005. 12. Attached hereto as Exhibit K is a true and correct copy of correspondence
from David A. Rammelt to Klaus Hamm, dated November 29, 2005. 13. I and other associates and paralegals involved in this case have been
reviewing Google' production in this case. Thus far, I understand we have identified seven entire s boxes of production, encompassing the bates ranges GOOGLE 10001 - 23369 and GOOGLE 25385 -27523, which contain nothing but third party trademark complaints and related materials received by Google. I understand that all of these documents are marked as "Confidential Attorneys'Eyes Only." In addition, Google has identified the bates range GGE 423-56829 as third party trademark complaints and related materials. We believe that all of these documents are marked as "Confidential - Attorneys'Eyes Only." Executed on December 22, 2005, at Chicago, Illinois. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. /s/ Caroline C. Plater Caroline C. Plater
ATTESTATION OF CONCURRENCE OF FILING I, Ethan B. Andelman, under penalty of perjury of the laws of the United States of America, attest that concurrence in the filing of this document has been obtained from each of the other signatories to this document.
/s/ Ethan B. Andelman Ethan B. Andelman
Case No. C03-5340 JF Declaration of Caroline C. Plater ISO Motion to Enforce Stipulated Protective Order DM_US\8294100.v1
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