LegalZoom.com, Inc. v. Rocket Lawyer, Inc.

Filing 5

RESPONSE (re 1 MOTION to Compel ) Nonparty Google Inc.'s Opposition to LegalZoom.com, Inc.'s Motion to Compel Compliance with Subpoena filed byGoogle Inc.. (Attachments: # 1 Declaration of Jacob T. Veltman, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9)(Kramer, David) (Filed on 1/20/2015)

EXHIBIT 9
TO THE DECLARATION OF
JACOB T. VELTMAN

From:
Sent:
To:
Subject:

Veltman, Jacob
Thursday, January 08, 2015 7:17 PM
Barak Vaughn
RE: LegalZoom adv. Google Ventures - Meet and Confer

Barak,
We felt that the last meet and confer call was treated like a box to be checked off by your colleagues rather than an
opportunity to address our objections and reach a compromise. We would prefer that you address our objections in
writing before we have another call. Specifically, what is your position regarding:
(a) why documents relating to the study are relevant given that the study did not relate to Rocket Lawyer
advertisements;
(b) why internal Google Ventures documents that were never seen by Rocket Lawyer are relevant;
(c) why communications between Google Ventures and Rocket Lawyer cannot be obtained from Rocket Lawyer;
(d) what documents you are seeking through Requests 2 & 3 (i.e., do you have any reason to believe that Google
Ventures possesses documents relating to Rocket Lawyer Free Advertisements unrelated to the study)
(e) whether and to what extent you are willing to share some or all of the cost Google Ventures would incur in
searching for and producing the documents requested; and
(f) how you believe Google Ventures could effectively search for “all documents” relating to Rocket Lawyer Free
Advertisements.
Jake
Fr :Barak Vaughn [mailto:[e-mail]]
om
Sen t
:Thursday, January 08, 2015 2:49 PM
To:Veltman, Jacob
Subj :LegalZoom adv. Google Ventures - Meet and Confer
ect

Jacob:
I would like to meet and confer with you regarding LegalZoom’s Subpoena to Google Ventures as well as Google
Ventures Responses and Objections to the Subpoena. Do you have any available time to have a telephonic meet and
confer conference on either Monday or Tuesday? Please let me know any available times you may have.
Respectfully,

Baa ughn
r kVa
10250 Constellation Blvd., 19th Floor, Los Angeles, CA 90067
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