Digital Envoy Inc., v. Google Inc.,

Filing 65

Attachment 1
EXHIBITS re 64 Brief in Opposition to Defendant Goggle, Inc.'s Motion to Shorten Time on the Hearing of its Protective Order filed byDigital Envoy,Inc.,, Digital Envoy,Inc.,. (Attachments: # 1 Exhibit B# 2 Exhibit C# 3)(Related document(s)64) (Blackman, Brian) (Filed on 1/20/2005)

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Case 5:04-cv-01497-RS Document 65-2 Filed 01/20/2005 Page 1 of 3 EXHIBIT B 1 W m 0 Case 5:04-cv-01497-RS 01/14/05 7 :13 Document 65-2 Filed 01/20/2005 Page 2 of 3 N0 .297 02 ILSON SONSINI GOODRICH ROSATI Wilson Sonsini Goodxich & Rosati PROFESSIONAL CORPORATION 650 Page Mill Read Palo Alto, CA 94304-1050 om 650 .493.9300 FAX 650A93.681 1 wwwwmcoz January 1.4, 200 5 Via Facsimile to (404) 443-5761 and U6 Mai l John A. Lockett lzl, Esq . McGuire Woods, LLP 1170 Peachtree Street, N.E. Suite 2140 Atlanta, Georgia 3030 9 Re : Digital Envoy v. Gaagle USDC, Nort hern District of California, Case No . : C-04.01497 US Dear John: I wri te loather to your letter of today and my letter of fanuaryl2 about the twenty-two (22) third-party subpoenas that Digital Envoy has served . Google maintains that the subpoenas are overbroad, vague, not calculated to lead to the discovery of admissible evidence, vexatious and harassing . You have not advanced any reasons why not. Google has been burdened and its business disrupted by having to field calls and enquiries from third part ies that you have subpoenaed . Several of the third parties have requested Google to take action seeking a protective order, which as I previously informed you, Google will be doing. In addition, your requests seek confidential, trade secret business information that has nothing to do with the issues in the Digital Envoy v. Google litigation. Your letter does not answer my straightforward question : what is the relevance to the issues in the present li tigation between Digital Envoy and Google of the incredibly overbroad document requests to third parties? All you have said is that the requests are relevant . We need an explanation tobl as to why, since the opposite seems obvious . We also request that you stipulate to an order sh ortening time on Google's motion for a protective order regarding the subpoenas as follows : · Google's motion for a protective order to be fi led on Tuesday, January 18 . · Digital Envoy's opposition to Google's motion to be filed by F ri day, January 21 . · Google's reply to be filed by Monday, January 24 . · Hearing before Judge Seeborg on Wednesday, Janua ry 26 . C:1NrportWU'AL1B 1\?BMW9052I _ 1 PAGE 213"RCVDAT 1114121105 8 :11 :58 PM ~ astem Standard Time] I WAIGHTFAYM t DNIS16321 C80 :650 565 51001 DU J T 1 W W D Case 5:04-cv-01497-RS 0 1 /14'05 7 :13 Document 65-2 Filed 01/20/2005 Page 3 of 3 NO .297 03 ILSON SONSINI GOODRI CH ROSATI Nilson Sonsini Goodrich & Rosari PROVESMONAL CORPOMAT1O N ohn A . I=ket, ITT, Esq . January 14, 2005 Page 2 PIease get back to me on the above proposed shortened briefing and hearing schedule by Tuesday, January 18 at 12 :00 p .m . PST . ILSON SONSINI GOODRICH & ROSATI Professional Corporation Stephen C . Holmes CC . imothy H . Kratz, Esq. P . Craig Cardon, Esq . ;1(VTy+pr{ bt{PALt6T5F6ty{t2144451i _ { .lf{7(: (t 7A PAGE 313' RCVD AT 1110005 8 :11 :58 PM (Eastern Standard Time]' SVR:FMTFAX123' D( :4632' CS10 :650 565 5100' DURATION (mm-ss) :0116

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