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

Filing 733

Declaration of Thomas B. Mason 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, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 731 ) (SeLegue, Sean) (Filed on 12/23/2009)

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Exhibit A 4 :0 M STREET, W iU fE ZUCKERMAN SPAE DE H LLP ff2 178i $00 202022 0f06xwwirjckerncmn Thomas B. Mason (202) 778-1844 September 8, 2009 Via Facsimile & Federal Express James E. Towery, Esquire Hoge, Fenton, Jones & Appel, Inc. 60 South Market Street Suite 1400 San Jose, CA 95113-2396 Dear Mr. Towery: presents Finnegan, As stated in my letter to you dated January 7, 2009, this firm re t to your request on behalf spec Henderson, Farabow, Garrett & Dunner LLP ("Finnegan") with re ve reviewed Judge Ware's September 2, 2009 order on of new ConnectU, Inc. for its files. We ha ith it promptly. this issue and wish to work cooperatively with you to comply w n, specifically, the Finnegan's representation of old ConnectU was limited to litigatio r)- Finnegan did not represent ia Massachusetts and California actions with which you are famil neral business affairs. Nevertheless, Finnegan obtained old ConnectU in connection with its ge iness activities in the course of its from old ConnectU some documents related to its general bus discovery requests from Facebook work in the litigations. Those documents were the subject of Facebook in discovery. in the litigations, and all such documents were provided to der Judge Ware's order The documents that need to be provided to new ConnectU un nnegan. Old ConnectU did not designate therefore have already been provided to Facebook by Fi orders entered in the cases. Facebook, any such documents as confidential under the protective ectU's sole director and officer, new ConnectU's sole owner, and the employer of new Conn ver to new ConnectU or any therefore not only has these documents but can turn them o procedure appears to us to be the ConnectU officer or employee without restriction. This order. Please let us know if you agree. quickest and most efficient way to satisfy Judge Ware's viously provided to Facebook are If, for some reason, the documents that have been pre set. unavailable to ConnectU, we can provide an additional ., No. C 07-0 1389 JW (N.D. Ca.); ConnectU. Inc. et at. i The Facebook, Inc., et at. v. Connect U, Inc., et at onnectU LLC et a!. v. Facebook et a!., No. 04-CV- 11923 Zuckerberg, et at., No. 07-CV- 10593 (D. Mass.); C (D.Mass.) WASHINGTON, DC 4EW `YORK AMPA 3ALTfMORE `1ILMfNGTON, 2E ZUCKERMAN SPAEDER LLP James E. Towery, Esquire September 8, 2009 Page 2 If you have any questions regardi the above, please contact me. Your7 omas B. Mason cc: I. Neel Chatterjee, Esquire Scott R. Mosko, Esquire John F. Hornick, Esquire 2356941.1

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