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

Filing 286

Declaration of Theresa A. Sutton in Support of Administrative Request for Order Requiring Defendants to Provide Deposition Dates 285 filed by Mark Zuckerberg, The Facebook, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Related document(s) 285 ) (Sutton, Theresa) (Filed on 1/30/2008) Text modified on 1/31/2008 conforming to posted document caption (bw, COURT STAFF).

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

D

Doc. 286 Att.

Exhibit E

OHS West:260138169.1

ockets.Justia.com

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Sutton, Theresa A.
From: Sent: To: Mosko, Scott [[e-mail]] Wednesday, January 23, 2008 11:50 AM Sutton, Theresa A.

Subject: RE: Request for deposition dates and times Theresa, We disagree that you cannot identify the appropriate witnesses based on the topics I have provided below. It appears you are refusing to make your witnesses available, and we will advise the Court accordingly.

Scott R. Mosko Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 3300 Hillview Avenue Palo Alto, California 94304-1203 PH: 650-849-6672 FAX: [phone] EMAIL: [e-mail]

From: Sutton, Theresa A. [mailto:[e-mail]] Sent: Wednesday, January 23, 2008 11:43 AM To: Mosko, Scott Cc: Cooper, Monte; Dalton, Amy Subject: RE: Request for deposition dates and times ScottI can't give you dates without first being able to identify the specific topics. Facebook has a number of employees and, depending on the topics, one person may be more appropriate than another. You'll need to serve a notice with topics, so if you can just provide those to me, I can get you dates. Theresa

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O
ORRICK Theresa A. Sutton Orrick, Herrington & Sutcliffe LLP Silicon Valley Office 1000 Marsh Road, Menlo Park, CA 94025 650.614.7307 (Voice) 650.614.7401 (Fax) [e-mail] www.orrick.com

1/30/2008

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From: Mosko, Scott [mailto:[e-mail]] Sent: Wednesday, January 23, 2008 11:24 AM To: Sutton, Theresa A. Subject: RE: Request for deposition dates and times Theresa, I cannot be any more specific at this time, other than what I have indicated. When are your witnesses available? Scott R. Mosko Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 3300 Hillview Avenue Palo Alto, California 94304-1203 PH: 650-849-6672 FAX: [phone] EMAIL: [e-mail]

From: Sutton, Theresa A. [mailto:[e-mail]] Sent: Wednesday, January 23, 2008 11:17 AM To: Mosko, Scott Cc: Cooper, Monte; Dalton, Amy Subject: RE: Request for deposition dates and times ScottPlease provide me more specific information regarding the 30(b)(6) topics so that Facebook can determine the most approrpriate witness(es). Theresa

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O
ORRICK Theresa A. Sutton Orrick, Herrington & Sutcliffe LLP Silicon Valley Office 1000 Marsh Road, Menlo Park, CA 94025 650.614.7307 (Voice) 650.614.7401 (Fax) [e-mail] www.orrick.com

1/30/2008

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From: Mosko, Scott [mailto:[e-mail]] Sent: Thursday, January 17, 2008 5:12 PM To: Sutton, Theresa A. Cc: Wagner, Valerie Subject: Request for deposition dates and times Theresa, Defendant ConnectU seeks to notice a Rule 30(b)(6) deposition of Facebook. Please provide us with dates and times you and Facebook are available. The general topics of inquiry will be the operation of Facebook's servers, and its internet connections from the time its website launched to the present. Please get back to me at your earliest opportunity. Thank you

Scott R. Mosko Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 3300 Hillview Avenue Palo Alto, California 94304-1203 PH: 650-849-6672 FAX: [phone] EMAIL: [e-mail]

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1/30/2008

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This e-mail message is intended only for individual(s) to whom it is addressed and may contain information that is privileged, confidential, proprietary, or otherwise exempt from disclosure under applicable law. If you believe you have received this message in error, please advise the sender by return e-mail and delete it from your mailbox. Thank you. This e-mail message is intended only for individual(s) to whom it is addressed and may contain information that is privileged, confidential, proprietary, or otherwise exempt from disclosure under applicable law. If you believe you have received this message in error, please advise the sender by return e-mail and delete it from your mailbox. Thank you.

1/30/2008