The Facebook, Inc. v. Connectu, Inc et al

Filing 229

Declaration of Yvonne Greer in Support of Reply Memorandum of Points and Authorities in Support of Facebook's Motion to Compel Pacific Northwest and Winston Williams to Provide Complete and Supplemental Responses to Facebook's First Set of Interrogatories Nos. 3 and 4; 222 filed by Mark Zuckerberg, The Facebook, Inc.. (Attachments: # 1 Exhibit M) (Related document(s) 222 ) (Greer, Yvonne) (Filed on 11/19/2007) Text modified on 11/20/2007 (bw, COURT STAFF).

The Facebook, Inc. v. Connectu, LLC et al

Doc. 229

Case 5:07-cv-01389-RS

Document 229

Filed 11/19/2007

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G. HOPKINS GUY, III (State Bar No. 124811) [e-mail] m I. NEEL CHATTERJEE (State Bar No. 173985) [e-mail] MONTE COOPER (State Bar No. 196746) [e-mail] m THERESA A. SUTTON (State Bar No. 211857) [e-mail] YVONNE P. GREER (State Bar No. 214072) [e-mail] ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: [phone] Facsimile: 650-614-7401 Attorneys for Plaintiffs FACEBOOK, INC. and MARK ZUCKERBERG UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

FACEBOOK, INC. and MARK ZUCKERBERG, Plaint iffs, v. CONNECTU, INC. (formerly known as CONNECTU, LLC), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, and DAVID GUCWA, Defendants.

Case No. 5:07-CV-01389-RS DECLARATION OF YVONNE P. GREER IN SUPPORT OF REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF FACEBOOK'S MOTION TO COMPEL PACIFIC NORTHWEST SOFTWARE AND WINSTON WILLIAMS TO PROVIDE COMPLETE AND SUPPLEMENTAL RESPONSES TO FACEBOOK'S FIRST SET OF INTERROGATORIES NOS. 3 AND 4 Date: Time: Judge: December 14, 2007 9:30 A.M. Hon. Richard Seeborg

OHS West:260340609.1

GREER DECL. TO REPLY ISO MOTION TO COMPEL 5:07-CV-01389-RS

Dockets.Justia.com

Case 5:07-cv-01389-RS

Document 229

Filed 11/19/2007

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I, Yvonne P. Greer, declare as follows: 1. I am an associate at the law firm of Orrick, Herrington & Sutcliffe, counsel for

Plaintiffs Facebook, Inc. and Mark Zuckerberg in this action, and a member of the Bar of the state of California. I make this declarat ion in support of the Reply Memorandum of Points and Authorities in Support of Facebook's Motion to Compel Pacific Northwest Software and Winston Williams to Provide Complete and Supplemental Responses to Facebook's First Set of Interrogatories Nos. 3 and 4. I make this declaration of my own personal knowledge and, if called as a witness, I could and would testify competently to the truth of the matters set forth herein. 2. Attached hereto as Exhibit M is a true and correct copy of a document produced

by iMarc at bates numbers iMarc001529-1531. Defendant Pacific Northwest Software, Inc. ("PNS") produced a version of this document at bates numbers PNS000556-558. 3. This document represents another example of the evidence provided in Section C

to Plaintiff Facebook, Inc.'s Reply Memorandum of Points and Authorities in Support of Facebook's Motion to Compel Pacific Northwest Software and Winston Williams to Provide Complete and Supplemental Responses to Facebook's First Set of Interrogatories Nos. 3 and 4 that proves that PNS' and Williams' prior responses to Interrogatories Nos. 3 and 4 are inco mplete. This document is an email from Cameron Winklevoss to several individuals involved with the development of the Facebook Importer and Social Butterfly programs. There are multiple references to the IP address 24.22.165.112 as being Winston Williams' own IP address. This IP address was not listed in either PNS' or Williams' prior responses to Interrogatories Nos. 3-4. I declare under penalty of perjury that the forgoing is true and correct to the bet of my knowledge. Executed this 19th of November, 2007, at Menlo Park, California.

/s/ Yvonne P. Greer /s/ Yvonne P. Greer

OHS West:260340609.1

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GREER DECL. TO REPLY ISO MOTION TO COMPEL 5:07-CV-01389-RS

Case 5:07-cv-01389-RS

Document 229

Filed 11/19/2007

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OHS West:260340609.1

CERTIFICATE OF SERVICE I hereby certify that this document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non registered participants on November 19 2007. Dated: November 19, 2007 Respect fully submitted, /s/ Yvonne P. Greer /s/ Yvonne P. Greer

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SUPPLEMENTAL DECL. TO REPLY ISO MOTION TO COMPEL 5:07-CV-01389-RS