Google Inc. et al v. Egger et al

Filing 73

Declaration of Jennifer A. Kash in Support of 72 Memorandum in Opposition, and Plaintiffs' Cross-Motion to Compel Production of Documents From Defendant Software Rights Archive, LLC filed byYahoo! Inc., IAC Search & Media, Inc., Lycos Inc., Google Inc., AOL LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)(Related document(s) 72 ) (Kash, Jennifer) (Filed on 2/3/2009)

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Google Inc. et al v. Egger et al Doc. 73 1 [SEE SIGNATURE BLOCK FOR COUNSEL] 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION CASE NO. CV 08-03172-RMW DECLARATION OF JENNIFER A. KASH IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO QUASH PLAINTIFFS' 30(b)(6) NOTICE OF DEPOSITION TO DEFENDANT SOFTWARE RIGHTS ARCHIVE, LLC AND PLAINTIFFS' CROSS-MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT SOFTWARE RIGHTS ARCHIVE, LLC Hearing Date: February 27, 2009 Hearing Time: 9:00 AM 11 GOOGLE INC., AOL LLC, YAHOO! INC., IAC SEARCH & MEDIA, INC., and 12 LYCOS, INC., 13 14 v. Plaintiffs, 15 L. DANIEL EGGER, SOFTWARE RIGHTS ARCHIVE, LLC, and 16 SITE TECHNOLOGIES, INC., 17 18 19 20 21 22 23 24 25 26 27 28 51429/2782180.1 Defendants. KASH DECLARATION IN SUPPORT OF PLAINTIFFS' OPPOSITION TO MOTION TO QUASH AND PLAINTIFFS' CROSS-MOTION TO COMPEL CASE NO. C-08-03172-RMW Dockets.Justia.com 1 I, Jennifer A. Kash, declare as follows: 2 1. I am an attorney admitted to practice in the State of California, and I am a partner 3 of the law firm of Quinn Emanuel Urquhart Oliver & Hedges, LLP. I represent Plaintiffs IAC 4 Search & Media, Inc. and Lycos, Inc. in this action. Except as otherwise stated, I have personal 5 firsthand knowledge of the matters set forth in this Declaration, and if called as a witness I would 6 testify competently to those matters. 7 2. Attached hereto as Exhibit A is a true and correct copy of Plaintiffs' Notice of 8 Deposition Pursuant to 30(b)(6) to Software Rights Archive, LLC, served on December 22, 2008. 9 3. Attached hereto as Exhibit B is a true and correct copy of Plaintiffs' First Set of 10 Requests for Production of Documents and Things to Software Rights Archive, LLC, served on 11 November 21, 2008. 12 4. Attached hereto as Exhibit C is a true and correct copy of Software Rights Archive, 13 LLC's Objections and Responses to Plaintiffs' First Set of Requests for Production of Documents 14 and Things, served on December 9, 2008. 15 5. Attached hereto as Exhibit D is a true and correct copy of a letter dated January 22, 16 2009 from Plaintiffs to Software Rights Archive, LLC. 17 6. Attached hereto as Exhibit E is a true and correct copy of a letter dated January 29, 18 2009 from Software Rights Archive, LLC to Plaintiffs. 19 7. Attached hereto as Exhibit F is a true and correct copy of the Joint Motion of the 20 Parties to Notify the Court of (1) Agreements Regarding Protective Order and (2) One Remaining 21 Dispute Regarding Protective Order, filed on November 4, 2008 in SRA, LLC v. Google et al., 22 Civil Case No. 2:07-cv-511 (CE) (E.D. Tex.). 23 8. Attached hereto as Exhibit G is a true and correct copy of the document available at 24 the following Internet address: http://www.visto.com/news/releases/pdfs/07.02.16_financing.pdf. 25 9. Attached hereto as Exhibit H is a true and correct copy Plaintiffs' Second Set of 26 Requests for Production of Documents and Things to Software Rights Archive, LLC, served on 27 December 12, 2008. 28 51429/2782180.1 KASH DECLARATION IN SUPPORT OF PLAINTIFFS' OPPOSITION TO MOTION TO QUASH AND PLAINTIFFS' CROSS-MOTION TO COMPEL CASE NO. C-08-03172-RMW 1 1 10. Attached hereto as Exhibit I is a true and correct copy of Software Rights Archive, 2 LLC's Objections and Responses to Plaintiffs' Second Set of Requests for Production of 3 Documents and Things, served on January 15, 2009. 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 51429/2782180.1 I declare under penalty of perjury that the foregoing is true and correct. Executed this 3rd day of February, 2009, at San Francisco, California. /s/ Jennifer A. Kash Jennifer A. Kash KASH DECLARATION IN SUPPORT OF PLAINTIFFS' OPPOSITION TO MOTION TO QUASH AND PLAINTIFFS' CROSS-MOTION TO COMPEL CASE NO. C-08-03172-RMW 2

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