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

Filing 54

Declaration of Scott R. Mosko in Support of Defendants Pacific Northwest Software, Inc. and Winston Williams' Opposition to Facebook's Motion for Expedited Discovery Re: Personal Jurisdiction filed byPacific Northwest Software, Inc., Winston Williams. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit F# 5 Exhibit G# 6 Exhibit H# 7 Exhibit I)(Mosko, Scott) (Filed on 4/25/2007)

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The Facebook, Inc. v. Connectu, LLC et al Doc. 54 Case 5:07-cv-01389-RS Document 54 Filed 04/25/2007 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 Scott R. Mosko (State Bar No. 106070) scott.mosko@finnegan.com FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. Stanford Research Park 3300 Hillview Avenue Palo Alto, California 94304 Telephone: (650) 849-6600 Facsimile: (650) 849-6666 Attorneys for Defendants Winston Williams and Pacific Northwest Software, Inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE FACEBOOK, INC. Plaintiff, v. CONNECTU LLC, (now known as CONNECTU INC.) PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, AND DOES 1-25, Defendants. CASE NO. C 07-01389 RS DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS PACIFIC NORTHWEST SOFTWARE, INC. AND WINSTON WILLIAMS' OPPOSITION TO FACEBOOK'S MOTION FOR EXPEDITED DISCOVERY RE: PERSONAL JURISDICTION Date: Time: Dept. Judge: May 16, 2007 9:30 a.m. 4 Honorable Richard Seeborg Doc. No. 461776 DEC. OF S. MOSKO ISO DEFENDANTS OPPOSITION TO FACEBOOK'S MOTION FOR EXPEDITED DISCOVERY CASE NO. C 07-01389 RS Dockets.Justia.com Case 5:07-cv-01389-RS Document 54 Filed 04/25/2007 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 I, Scott R. Mosko declare, 1. I am an attorney duly licensed to practice law in the state of California and am a member of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, attorneys of record for Defendants Winston Williams and Pacific Northwest Software, Inc. The matters referred to in this declaration are based on my personal knowledge and if called as a witness I could, and would, testify competently to those matters. 2. Attached hereto as Exhibit A is a true and correct copies of certain pages of testimony from the deposition of ConnectU LLC, taken in the Massachusetts District Court Action on August 9, 2005. 3. Attached hereto as Exhibit B is a true and correct copy of Facebook's First Set of Special Interrogatories to Cameron Winklevoss, served November 3, 2005. 4. Attached hereto as Exhibit C is a true and correct copy of an Amended Response of Cameron Winklevoss to Facebook's First Set of Special Interrogatories, served March 9, 2006. 5. Attached hereto as Exhibit D is a true and correct copies of certain pages of testimony from the deposition of ConnectU LLC, taken in the pending action on January 16, 2006. (FILED UNDER SEAL) 6. Attached hereto as Exhibit E is a true and correct copies of certain pages of testimony from the deposition of Pacific Northwest Software, taken in the pending action on January 29, 2007 (FILED UNDER SEAL). 7. Attached hereto as Exhibit F is a true and correct copy of an Order Denying Motion to Advance Case Management Conferences and Related Dates, filed April 13, 2007. 8. Attached hereto as Exhibit G is a true and correct copy of an email from Theresa Sutton to Scott Mosko regarding discovery scheduling, dated April 12, 2007. 9. Attached hereto as Exhibit H is a true and correct copy of an email from Scott Mosko to Theresa Sutton regarding discovery scheduling, dated April 12, 2007 10. Attached hereto as Exhibit I is a true and correct copy of an email from Theresa Sutton to Scott Mosko regarding discovery scheduling, dated April 13, 2007. DEC. OF S. MOSKO ISO DEFENDANTS OPPOSITION TO FACEBOOK'S MOTION FOR EXPEDITED DISCOVERY CASE NO. C 07-01389 RS Doc. No. 461776 1 Case 5:07-cv-01389-RS Document 54 Filed 04/25/2007 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 under the laws of the United States that the foregoing is true and correct, and that this declaration was executed on the 25th day of April, 2007, in Palo Alto, California. /s/ Scott R. Mosko Scott R. Mosko Attorneys for Defendants Winston Williams and Pacific Northwest Software, Inc. Doc. No. 461776 2 DEC. OF S. MOSKO ISO DEFENDANTS OPPOSITION TO FACEBOOK'S MOTION FOR EXPEDITED DISCOVERY CASE NO. C 07-01389 RS

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