Campbell et al v. Facebook Inc.

Filing 109

MOTION for Extension of Time to File Plaintiffs' Motion for Extension of Class Certification and Summary Judgment Deadlines filed by Matthew Campbell, Michael Hurley. (Attachments: # 1 Proposed Order, # 2 Declaration of David Rudolph, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Exhibit 12, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 19, # 22 Exhibit 20, # 23 Exhibit 21)(Sobol, Michael) (Filed on 9/16/2015)

EXHIBIT 11

May 27, 2015
VIA E-MAIL
Joshua Jessen, Esq.
Gibson, Dunn & Crutcher LLP
[e-mail]
Christopher Chorba, Esq.
Gibson, Dunn & Crutcher LLP
[e-mail]
RE:

Campbell v. Facebook, Inc., N.D. Cal. Case No. 13-cv-05996-PJH

Dear Josh:
I am writing in response to your letter of May 13, 2015. Concerning the initial, six custodians
identified in the first paragraph of your letter – Michael Adkins, Alex Himel, Ray He, Matt Jones, Jordan
Blackthorne, and Peng Fan – at first glance, that list seems small. However, in light of your statement
that you are identifying additional parties, we will reevaluate the sufficiency of your list of custodians
once we’ve received your June 1, 2015, production and have had a chance to conduct initial depositions.
Thank you for providing the list of proposed search terms in the Appendix to your letter. At this
time, prior to review of the initial production of internal documents, we have no additional search terms to
propose.
We appear to have reached an impasse on several issues: (1) your objections to Plaintiffs’
Requests for Production Nos. 27, 28, and 30; (2) the beginning date to the Relevant Time Period of
Plaintiff’s discovery requests; and (3) deposition dates in early-to-mid June for Jiakai Liu and the
declarant to your forthcoming production. We would like to schedule an in-person meet and confer
within the week regarding these points. What is your availability tomorrow or Friday?
Sincerely,

Hank Bates
HB/jcg

2800 Cantrell Road, Suite 510 | Little Rock, AR 72202
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