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

Filing 68

Declaration of Carline C. Plater in Support of 67 MOTION to Compel Defendant's Notice of Motion and Motion to Compel Compliance with F.R.C.P. 34(b) 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)(Related document(s)67) (Andelman, Ethan) (Filed on 12/23/2005)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 68 Case 5:03-cv-05340-JF Document 68 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 68 Filed 12/23/2005 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 & 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 American Blind & Wallpaper Factory, Inc.' First Set of Requests for Production of Documents and Things to s Google, Inc., dated April 20, 2005. 3. Attached hereto as Exhibit B is a true and correct copy of Plaintiff and Counter-Defendant Google Inc.' Responses and Objections to American Blind & Wallpaper s Factory, Inc.' First Set of Requests for Production of Documents and Things to Google, Inc., s dated June 21, 2005. 4. Attached hereto as Exhibit C is a true and correct copy of an e-mail from David A. Rammelt to Klaus Hamm, dated November 29, 2005. 5. Attached hereto as Exhibit D is a true and correct copy of correspondence from Klaus Hamm to David A. Rammelt, dated November 29, 2005. 6. Attached hereto as Exhibit E is a true and correct copy of Google Inc.' s Responses and Objections to Defendant and Counter-Plaintiff American Blind & Wallpaper Factory, Inc.' First Set of Interrogatories, dated June 21, 2005. s 7. Attached hereto as Exhibit F is a true and correct copy of correspondence from Klaus Hamm to David A. Rammelt, dated December 5, 2005. 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 Case No. C03-5340 JF Declaration of Caroline C. Plater ISO Motion to Enforce Stipulated Protective Order DM_US\8294178.v1 -2- Case 5:03-cv-05340-JF Document 68 Filed 12/23/2005 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 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\8294178.v1 -3-

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