Specht et al v. Google Inc et al

Filing 338

NOTICE of Motion by Herbert H. Finn for presentment of motion for protective order 337 before Honorable Harry D. Leinenweber on 5/12/2011 at 09:30 AM. (Finn, Herbert)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
ERICH SPECHT, et al.,

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Plaintiffs,
v.
GOOGLE INC.,
Defendant.

Civil Action No. 09-cv-2572
Judge Leinenweber
Magistrate Judge Cole

NOTICE OF MOTION
TO:

Martin J. Murphy ([e-mail])
2811 RFD
Long Grove, IL 60047
PLEASE TAKE NOTICE that on Thursday, May 12, 2011, at 9:30 a.m. or as soon

thereafter as counsel may be heard, the undersigned will appear before the Honorable Judge
Leinenweber, or any Judge sitting in his stead, in Courtroom 1941, at 219 South Dearborn Street,
Chicago,

Illinois

and

present

GOOGLE

INC.’S

MOTION

AND

SUPPORTING

MEMORANDUM FOR A PROTECTIVE ORDER REQUIRING PLAINTIFFS TO DESTROY
ATTORNEY CLIENT

PRIVILEGED/WORK PRODUCT

IMMUNE

INFORMATION

INADVERTENTLY PRODUCED BY GOOGLE, a copy of which is being served on you
herewith.

CHI 61,026,090v1 5-9-11

Respectively submitted,
Dated: May 9, 2011

/s Herbert H. Finn
Herbert H. Finn (ARDC #6205685)
Jeffrey P. Dunning (ARDC #6273364)
Cameron M. Nelson (ARDC #6275585)
GREENBERG TRAURIG, LLP
77 West Wacker Drive, Suite 3100
Chicago, IL 60601
[phone]
COUNSEL FOR GOOGLE INC.

CERTIFICATE OF SERVICE
I hereby certify that on the date set forth below, I electronically filed the foregoing
NOTICE OF MOTION and GOOGLE INC.’S MOTION AND SUPPORTING
MEMORANDUM FOR A PROTECTIVE ORDER REQUIRING PLAINTIFFS TO DESTROY
ATTORNEY CLIENT PRIVILEGED/WORK PRODUCT IMMUNE INFORMATION
INADVERTENTLY PRODUCED BY GOOGLE with the Clerk of Court using the CM/ECF
system, which will send notification of such filings to all counsel of record.

Dated: May 9, 2011

CHI 61,026,090v1 5-9-11

/s Herbert H. Finn

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