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

Filing 732

Declaration of Sean M. SeLegue in Support of 731 Objection, to and Motion to Strike, ConnectU's Renewed Request For Hearing Date Relating to Production of ConnectU's Documents filed byDivya Narendra, Cameron Winklevoss, Tyler Winklevoss. (Attachments: # 1 Exhibit A)(Related document(s) 731 ) (SeLegue, Sean) (Filed on 12/23/2009)

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The Facebook, Inc. v. Connectu, LLC et al Doc. 732 Case5:07-cv-01389-JW Document732 Filed12/23/09 Page1 of 2 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 JEROME B. FALK, JR. (No. 39087) Email: SEAN M. SELEGUE (No. 155249) Email: JOHN P. DUCHEMIN (No. 250501) Email: HOWARD RICE NEMEROVSKI CANADY FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4024 Telephone: 415/434-1600 Facsimile: 415/677-6262 Attorneys for CAMERON WINKLEVOSS, TYLER WINKLEVOSS and DIVYA NARENDRA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE FACEBOOK, INC., et al., Plaintiffs, v. CONNECTU, INC., et al., Defendants. No. C 07-01389 JW DECLARATION OF SEAN M. SELEGUE IN SUPPORT OF CONNECTU FOUNDERS' OBJECTION TO, AND MOTION TO STRIKE, CONNECTU'S RENEWED REQUEST FOR HEARING DATE RELATING TO PRODUCTION OF CONNECTU'S DOCUMENTS Chief Magistrate Judge Maria-Elena James (San Francisco Division) SELEGUE DECL. ISO OBJ. TO RENEWED REQUEST FOR HEARING DATE C 07-01389-JW Case5:07-cv-01389-JW Document732 Filed12/23/09 Page2 of 2 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, Sean M. SeLegue , declare as follows: 1. I am an attorney admitted to practice before this Court, and a shareholder and director in the law firm of Howard Rice Nemerovski Canady Falk & Rabkin, A Professional Corporation ("Howard Rice"), which is counsel to ConnectU Founders Cameron Winklvoss, Tyler Winklevoss and Divya Narendra (the "Founders"). Unless otherwise indicated, the facts stated herein are true and correct to my own personal knowledge, and if called as a witness, I could and would competently testify thereto. 2. On December 22, 2009, I called James Towery of Hoge, Fenton, Jones & Appel, Inc., counsel for ConnectU, Inc. ("ConnectU") in this matter, to discuss the "Renewed Request For Hearing Date Relating To Production of ConnectU's Documents" that ConnectU filed on December 22, 2008 (the "Renewed Request"). I asked Mr. Towery to withdraw the request in light of the Court's direction that the parties meet and confer and file a joint status report once the Ninth Circuit ruled on whether the Founders' appeal of Judge Ware's disqualification order should remain pending. I also expressed concern that ConnectU's Renewed Request could be confusing in stating that the Founders' appeal of the disqualification appeal had been dismissed without also noting that the Ninth Circuit had effectively consolidated the appeal with other pending appeals. Mr. Towery said he would discuss the matter with his clients and get back to me. 3. Shortly after the call, I emailed Mr. Towery to seek confirmation that the Renewed Request would be withdrawn. Mr. Towery responded that he could not assure an answer by noon. Accordingly, we proceeded to file this objection and motion to strike. Attached hereto as Exhibit A is a true and correct copy of my email exchange today with Mr. Towery. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 23rd day of December, 2009, in San Francisco, California. /s/ SEAN M. SELEGUE W03 122309-180060001/U10/1600407/v1 SELEGUE DECL. ISO OBJ. TO RENEWED REQUEST FOR HEARING DATE C 07-01389-JW -1-

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