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

Filing 48

Declaration of Patrick Doolittle in Support of 47 First MOTION to Compel Documents filed byFusion Garage PTE. LTD. (Attachments: # 1 Exhibit)(Related document(s) 47 ) (Doolittle, Patrick) (Filed on 4/2/2010)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Claude M. Stern (Bar No. 96737) 2 Patrick Doolittle (Bar No. 203659) 3 50 California Street, 22nd Floor 4 San Francisco, California 94111 Telephone: (415) 875-6600 Facsimile: (415) 875-6700 5 6 Attorneys for Defendant Fusion Garage PTE. Ltd 7 8 9 10 11 12 INTERSERVE, INC. dba TECHCRUNCH, a Delaware corporation, and CRUNCHPAD, 13 INC., a Delaware corporation, 14 15 vs. Plaintiffs, CASE NO. 09-cv-5812 RS (PVT) DECLARATION OF PATRICK DOOLITTLE IN SUPPORT OF MOTION TO COMPEL PLAINTIFFS' COMPLIANCE WITH THEIR RESPONSES TO REQUESTS FOR PRODUCTION Date: TBD Time: 10:00 a.m. Judge: Hon. Patricia Trumbull UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 16 FUSION GARAGE PTE. LTD, a Singapore company, 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 04049.51632/3419139.1 1 2 I, PATRICK C. DOOLITTLE declare as follows: 1. I am a member of the bar of the State of California and a partner in Quinn Emanuel 3 Urquhart & Sullivan, LLP, attorneys for Defendant Fusion Garage. Unless otherwise noted, I 4 make this declaration of personal knowledge, and if called and sworn as a witness, I could and 5 would testify competently thereto. 6 2. Attached hereto as Exhibit A is a true and correct of Fusion Garage's Requests for 7 Production of Documents (Set One), dated January 8, 2010. 8 3. Plaintiffs served their initial Responses to Fusion Garage's Requests for Production 9 on or about February 8, 2010. 10 4. Attached hereto as Exhibit B is a true and correct copy of a meet and confer letter 11 dated March 10, 2010 that I sent Plaintiffs regarding certain deficiencies in Plaintiffs' discovery 12 responses. 13 5. Attached hereto as Exhibit C is a true and correct copy of a letter that Matthew 14 Scherb, Plaintiffs' counsel, sent on March 12, 2010 in response to my March 10, 2010 letter. 15 6. Attached hereto as Exhibit D is a true and correct copy of Plaintiffs' Supplemental 16 Responses to Fusion Garage's Request for Production of Documents (Set One), dated March 19, 17 2010. 18 7. On or about March 11, 2010, I met and conferred with plaintiffs' counsel about 19 discovery matters. Plaintiffs' counsel represented that we would be receiving documents on or 20 about March 12, 2010 and that we would have the bulk of the key documents by the week of 21 March 15. 22 8. Attached hereto as Exhibit E is a true and correct copy of a March 30, 2010 email 23 exchange between David Bloch, counsel for Plaintiffs, and me regarding the parties' document 24 production. 25 9. Attached hereto as Exhibit F is a true and correct copy of a March 31, 2010 letter 26 from me to David Bloch and Matthew Scherb regarding plaintiffs' document production and 27 interrogatory responses. 28 -2- 04049.51632/3419139.1 1 10. Attached hereto as Exhibit G is a true and correct copy of a March 31 to April 1 e-mail 2 exchange between myself and David Bloch regarding plaintiffs' document production. 3 11. Attached hereto as Exhibit H is a true and correct copy of an April 2, 2010 letter 4 from Matthew Scherb to me and Joshua Sohn regarding the status of document production and 5 Fusion Garage's concerns with TechCrunch's interrogatory responses. 6 12. Attached hereto as Exhibit I is a true and correct copy of an April 2, 2010 letter that 7 I sent to Matthew Scherb inquiring yet again when we would be receiving plaintiffs' document 8 production. 9 10 13. 14. To date, Plaintiffs have only produced approximately 330 pages of documents. The following time modifications have thus far been ordered in this case: (a) the 11 Court granted expedited discovery before the Rule 26(f) conference (Dkt. 19); and (b) the Court 12 set the hearing on Fusion Garage's Motion to Dismiss, to Strike, and For a More Definite 13 Statement (Dkt. 20) from May 3, 2010 to May 6, 2010 (Dkt. 45). 14 I declare under penalty of perjury under the laws of the United States of America that the 15 foregoing is true and correct. 16 17 18 19 20 21 22 23 24 25 26 27 28 -3Executed this 2nd day of April 2010 at San Francisco, California. /s/ Patrick C. Doolittle Patrick C. Doolittle 04049.51632/3419139.1

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