The Facebook, Inc. v. Connectu, Inc et al
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)
1BOOMSTREE'T,NW WASHINGTON, DC 20036-5807 202 822 8106 Ix www zuckerrn3n corn
Thomas B. Mason (2O2 778-1844 tmason@zuckermancom
September 23, 2009
Via E-Mail and Regular Mail
Allison P. Buchanan, Esquire Hoge, Fenton, Jones & Appel, Inc. 60 South Market Street, Suite 1400 San Jose, California 95113 Dear Ms. Buchanan: I write in response to your letter of September 8, 2009. 1 enclose an index to the ConnectU documents produced to Facebook in the Massachusetts litigation. No such index was prepared for the ConnectU documents produced to Facebook in the California litigation. However, I am informed that such production totaled only 3,178 pages of documents, and thus can be quickly reviewed by your office. I do not enclose an index or a log of Finnegan Henderson's litigation files, Judge Ware's order does not require such a document. An index, covering five years of litigation files, would be exceptionally burdensome and wasteful to prepare and would also prejudice the rights of the Founders, Because the Founders' rights are involved, please direct any further communications on this matter to both Mr. SeLegue and me. Sincerely,
Thomas B. Mason TBM:gbh Enclosure cc: John F. Hornick, Esquire (w/encL) Scott R. Mosko, Esquire (w/encl.) Sean M. SeLegue, Esquire (w/o end.)
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