Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 227

Declaration of J. Caleb Donaldson in Support of 226 Response to Motion to Compel filed by CrunchPad, Inc., Interserve, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) 226 ) (Donaldson, John) (Filed on 12/2/2011) Modified on 12/6/2011 (gba, COURT STAFF).

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WINSTON & STRAWN LLP
David S. Bloch (SBN: 184530)
[e-mail]
J. Caleb Donaldson (SBN: 257271)
[e-mail]
101 California Street
San Francisco, CA 94111-5802
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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SAN FRANCISCO DIVISION

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TECHCRUNCH, INC., et al.

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Plaintiffs,
vs.
FUSION GARAGE PTE. LTD.,

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Defendant.

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Case No. C 09-cv-05812-RS (PSG)
DECLARATION OF J. CALEB
DONALDSON IN SUPPORT OF
PLAINTIFFS’ OPPOSITION TO FUSION
GARAGE’S MOTION TO COMPEL
PRODUCTION OF DOCUMENTS
Date:
Time:
Judge:
Location:

January 3, 2012
10:00 a.m.
Hon. Paul Singh Grewal
San Jose, Courtroom 5, 4th
Floor

I, J. Caleb Donaldson, declare pursuant to 28 U.S.C. § 1746 under penalty of perjury that the
following is true and correct:
1.

I an associate with the law firm of Winston & Strawn LLP, counsel of record for

Plaintiffs in this action.
2.

Attached as Exhibit A is a true and correct copy (with highlighting added) of an email

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from Chandrasekar Rathakrishnan to Jonathan Bloom that Defendant produced in the course of

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discovery in this case.

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3.

Attached as Exhibit B is a true and correct copy of the docket sheet for Calacanis v.

Interserve, Inc. dba TechCrunch, Case Number CGC-10-505374 in California Superior Court, San
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DEC. OF J. DONALDSON ISO PLTF’S OPP. TO DEF.’S M/COMPEL PROD. OF DOCS CASE NO. C 09-CV-5812-RS (PSG)
SF:324328.1

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Francisco County.

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4.

Attached as Exhibit C is a true and correct copy of an email (with highlighting added)

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from Jonathan Bloom to Chandrasekar Rathakrishnan that Defendant produced in the course of

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discovery in this case.

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Executed on December 2, 2011.
/s/
J. Caleb Donaldson

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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DEC. OF J. DONALDSON ISO PLTF’S OPP. TO DEF.’S M/COMPEL PROD. OF DOCS CASE NO. C 09-CV-5812-RS (PSG)
SF:324328.1