CLRB Hanson Industries, LLC et al v. Google Inc.

Filing 333

MOTION to Compel Depositions of Objectors Randy R. Lyons, Chase Thompson, Etech Digital Playroom, Inc., and Universal Pro Audio, LLC, filed by CLRB Hanson Industries, LLC. Motion Hearing set for 9/8/2009 10:00 AM in Courtroom 5, 4th Floor, San Jose. (Attachments: # 1 Proposed Order, # 2 Declaration of Daniel J. Shih, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F)(Shih, Daniel) (Filed on 8/4/2009)

CLRB Hanson Industries, LLC et al v. Google Inc.

Doc. 333 Att. 3

Case5:05-cv-03649-JW Document333-4

Filed08/04/09 Page1 of 2

EXHIBIT B

Dockets.Justia.com

Page 1 of 1 Case5:05-cv-03649-JW Document333-4 Filed08/04/09 Page2 of 2

Daniel Shih
From: Sent: To: Cc: Daniel Shih July 22, 2009 9:46 AM Steve Miller Jack W. West; Rachel S. Black

Subject: CLRB Hanson v. Google

Dear Mr. Miller, We have received your letter of July 21, 2009, which confirmed your receipt of the class representatives' notice of depositions and subpoenas of your clients Randy R. Lyons and Chase Thompson. Your letter fails to note that, when Rachel Black spoke with you on Monday before you were served with the subpoenas, she asked you for an alternative date that would work for your clients, and you refused to provide one. Please provide alternative dates by the close of business Wednesday, along with your clients' AdWords account numbers. Also, you have not responded to my letter of July 17, 2009, asking that you provide the information required by the Court for bringing an objection so that we may verify that your clients are class members with standing to object. We therefore intend to ask the Court to disregard your objection for failure to abide by the Court's requirements. Kind regards, -Dan Shih
-----------------------------------------------------------Daniel J. Shih Attorney at Law [e-mail] 206-373-7390 (direct) / 206-516-3883 (fax)

SUSMAN GODFREY LLP 1201 Third Avenue, Suite 3800 Seattle, WA 98101

8/3/2009