Netquote Inc. v. Byrd

Filing 93

Attachment 3
MOTION for Leave to Take Additional Depositions, to Extend Discovery, and Modify the Scheduling Order by Defendant, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Continuation of Main Document LR 7.1 Certificate)(Isenberg, Ryan)

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Netquote Inc. v. Byrd Doc. 93 Att. 3 Case 1:07-cv-00630-DME-MEH Document 93-4 Filed 10/18/2007 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE INC, a Colorado corporation, Plaintiff, v. BRANDON BYRD, an internet user making use of the IP Addresses and, and MOSTCHOICE.COM, Inc., a Georgia corporation Defendants. AMENDED NOTICE OF DEPOSITION OF PLAINTIFF PURSUANT TO F.R.C.P. 30(B)(6) NOTICE OF DEPOSITION To: Netquote, Inc. PLEASE TAKE NOTICE that Defendant, Inc. will take the deposition of Plaintiff Netquote, Inc. ("plaintiff") pursuant to F.R.C.P. 30(b)(6) before an authorized court reporter at 9:00 o'clock a.m. on Tuesday, September 25, 2007 at the office of the counsel for the plaintiff. Pursuant to F.R.C.P. 30(b)(3) Mostchoice will videotape this deposition. Defendant is requested, pursuant to said Rule, to designate one or more of its officers, directors, or managing agents or other persons who consent to testify about matters known or reasonably available. The matters on which each person so designated will be examined will include the following: Page 1 of 4 Case 1:07-cv-00630-DME-MEH Document 93-4 Filed 10/18/2007 Page 2 of 4 1. 2. 3. 4. 5. 6. 7. 8. 9. All factual allegations raised in the plaintiff's complaint, as amended. Netquote's Affiliate program Netquote's Lead filtering system The manner and method of the collection and disbursal of leads Netquote's computer system relating to the collection and disbursal of leads Neqtuote's credit programs Netquote's communications with Melissa Buschacher Familiarity with Netquote's reputation Knowledge of alleged false leads, the identity of and communication with the recipients thereof 10. Internal communications relating to the false leads alleged to have caused harm to Netquote 11. 12. Internal communications and processes related to the receipt of bad leads Internal communications related to leads that were subsequently discovered to be submissions from Brandon Byrd 13. 14. 15. 16. 17. 18. 19. Efforts made to intercept and identify the submissions by Brandon Byrd Netquote's historical general financial information Netquote's historical lead generation and disbursal data Data concerning Netquote's lead quality Identity of former and current Netquote employees Information related to the quality of Mostchoice leads Information related to the quality of Netquote leads Page 2 of 4 Case 1:07-cv-00630-DME-MEH Document 93-4 Filed 10/18/2007 Page 3 of 4 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. Netquote's National account relations Netquote's Sales staff policy Netquote's knowledge of the insurance lead generation industry Discussions with representatives of bankrate Netquote's communications with third parties about this lawsuit Netquote's communications with third parties about Mostchoice Netquote's communications with Mostchoice Netquote's Cost of lead generation Netquote's Cost of lead disbursal Netquote's Cost of creating filtering systems Netquote's Cost of customer acquisitions Netquote's Customer retention Netquote's Customer Service Plaintiff's claims for damages Documents produced by plaintiff in response to discovery Netquote's business model Netquote's website, website management, and website content Netquote's internet protocol addresses Page 3 of 4 Case 1:07-cv-00630-DME-MEH Document 93-4 Filed 10/18/2007 Page 4 of 4 Dated this 21ST day of September, 2007. s/ Ryan Isenberg Ryan L. Isenberg, Esq. Isenberg & Hewitt, P.C. 7000 Peachtree Dunwoody Road Building 15, Suite 100 Atlanta, Georgia 30328 Telephone: 770-351-4400 Facsimile: 770-828-0100 (Fax) Email: CERTIFICATE OF SERVICE I hereby certify that on September 21, 2007, I served the foregoing Notice of Deposition by electronic delivery, as an attachment to an email, to the following counsel of record: David W. Stark Daniel D. Williams FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 s/ Ryan Isenberg Page 4 of 4

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