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)

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Daniel Shih
From: Sent: To: Cc: Daniel Shih August 03, 2009 2:12 PM 'Steve Miller' Rachel S. Black; Jack W. West

Subject: RE: Google Class Action: Motion for Protective Order

Steve, please consider the notice and subpoenas withdrawn. 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
From: Steve Miller [mailto:[e-mail]] Sent: August 03, 2009 1:41 PM To: Rachel S. Black; Daniel Shih Subject: Google Class Action: Motion for Protective Order

Rachel and Daniel, Without my consent you scheduled the depositions of my clients, Messrs. Lyons and Thompson for August 5, 2009 in Birmingham, Alabama. This is the second time you have tried to force their depositions without an agreed upon schedule. I asked you to withdraw the subpoenas by the end of last week; you have not done so. Please be advised that this afternoon I will be filing a Motion for Protective Order in the U.S. District Court, Northern District of California (San Jose Division). A similar Motion to Quash is being filed this afternoon in the U.S. District Court for the Northern District of Alabama. Messrs. Lyons and Thompson and I will not be appearing for their depositions on August 5, 2009. Steve Miller

8/3/2009