Netscape Communications Corporation et al v. Federal Insurance Company et al

Filing 58

Declaration of Michael Bruce Abelson In Support Of Plaintiffs' Motion to Compel filed byNetscape Communications Corporation, American Online, Inc.. (Attachments: # 1 Exhibit)(Hsu, Hway-Ling) (Filed on 10/16/2006)

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Netscape Communications Corporation et al v. Federal Insurance Company et al Doc. 58 Case 5:06-cv-00198-JW Document 58 Filed 10/16/2006 Page 1 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 ABELSON | HERRON LLP Michael Bruce Abelson (State Bar No. 130739) Leslie A. Pereira (State Bar No. 180222) 333 South Grand Ave, Suite 650 Los Angeles, California 90071-1559 Telephone: (213) 402-1900 Facsimile: (213) 402-1901 mabelson@abelsonherron.com lpereira@abelsonherron.com BERGESON, LLP Daniel J. Bergeson (State Bar No. 105439) Hway-ling Hsu (State Bar No. 196178) 303 Almaden Boulevard, Suite 500 San Jose, California 95110-2712 Telephone: (408) 291-6200 Facsimile: (408) 297-6000 dbergeson@be-law.com hhsu@be-law.com Attorneys for Plaintiff NETSCAPE COMMUNICATIONS CORP. and AMERICA ONLINE, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ­ SAN JOSE DIVISION NETSCAPE COMMUNICATIONS CORPORATION, et al., Plaintiffs, v. Motion Heard FEDERAL INSURANCE COMPANY, et al., Defendants. Date: Time: Judge: Dept: October 17, 2006 10:00 a.m. Magistrate Trumbull Courtroom 5 (Fourth Floor) CASE NO. C-06-00198 JW (PVT) DECLARATION OF MICHAEL BRUCE ABELSON IN SUPPORT OF PLAINTIFFS' MOTION TO COMPEL Complaint filed December 12, 2005 USDC CASE NO. C-06-00198 JW (PVT) DECLARATION OF MICHAEL BRUCE ABELSON IN SUPPORT OF PLAINTIFFS' MOTION TO COMPEL Dockets.Justia.com Case 5:06-cv-00198-JW Document 58 Filed 10/16/2006 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 DECLARATION OF MICHAEL BRUCE ABELSON I. Michael Bruce Abelson, declare as follows: 1. I am an attorney licensed to practice law in the State of California, and before the bar of this Court. In that capacity, I am counsel to Plaintiffs Netscape Communications Corporation and America Online, Inc. in the above-captioned action between Plaintiffs and St. Paul Mercury Insurance Company. 2. Pursuant to this Court's Interim Order Re: Plaintiffs' Motion to Compel (dated November 16, 2006) and Civil Local Rule 7-5(a), attached hereto as Exhibit A is a true and correct copy of the disputed discovery requests (and responses) which are the subject of the Plaintiffs' Motion to Compel, scheduled to be heard by the Court on Tuesday, October 17, 2006. Exhibit A is the stipulated end product of a lengthy meet and confer process between counsel that narrowed the scope of the parties' dispute. Exhibit A accurately reflects the current positions of the parties, and differs substantially from the original request and responses. The attached Exhibit A replicates ­ without change or alteration ­ the Exhibit A attached to Plaintiffs' Motion to Compel, presently on file with the Court. 3. Attached hereto as Exhibit B is a true and correct copy of St. Paul's privilege log in this matter. (For the court's convenience, I have marked Exhibit B with black pen to highlight the exhibit's reference to James Zacharski). The attached Exhibit B replicates ­ without change or alteration ­ the Exhibit B attached to Plaintiffs' Motion to Compel, presently on file with the Court. /// /// /// /// /// DECLARATION OF MICHAEL BRUCE ABELSON IN SUPPORT OF PLAINTIFFS' MOTION TO COMPEL 2 Case 5:06-cv-00198-JW Document 58 Filed 10/16/2006 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 I declare under penalty of perjury of the laws of the United States of America that the foregoing is true and correct. Executed this 16th day of October 2006 at Los Angeles, California. ______________________/s/_________________________ Michael Bruce Abelson DECLARATION OF MICHAEL BRUCE ABELSON IN SUPPORT OF PLAINTIFFS' MOTION TO COMPEL 3

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