Connectu, Inc. v. Facebook, Inc. et al

Filing 135

DECLARATION re #132 MOTION to Compel Plaintiffs to Image and Search Their Memory Devices For Source Code, And To Comply with Requests for Production Nos. 102, 67-68 and 117 by Dustin Moskovitz, Andrew McCollum, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Exhibit 1A#2 Exhibit 1B#3 Exhibit 2#4 Exhibit 3, 4, 20, 21, and 22 (UNDER SEAL)#5 Exhibit 5#6 Exhibit 6#7 Exhibit 7#8 Exhibit 8#9 Exhibit 9#10 Exhibit 10#11 Exhibit 11#12 Exhibit 12#13 Exhibit 13#14 Exhibit 14#15 Exhibit 15#16 Exhibit 16#17 Exhibit 17#18 Exhibit 18A#19 Exhibit 18B#20 Exhibit 18C#21 Exhibit 19A#22 Exhibit 19B#23 Exhibit 23#24 Exhibit 24#25 Exhibit 25)(Sutton, Theresa) Additional attachment(s) added on 10/26/2007 (Nici, Richard).

Connectu, Inc. v. Facebook, Inc. et al

Doc. 135 Att. 8

Case 1:07-cv-10593-DPW

Document 135-9

Filed 10/24/2007

Page 1 of 2

EXHIBIT 8

Dockets.Justia.com

Page 1 of 1 Case 1:07-cv-10593-DPW Document 135-9 Filed 10/24/2007 Page 2 of 2

Dalton, Amy
To: Sutton, Theresa A.

Subject: RE: ConnectU v. Facebook, Case No. 07-10593 DPW

From: Schoenfeld, Meredith [mailto:[e-mail]] Sent: Thursday, July 12, 2007 8:03 AM To: Chatterjee, I. Neel; Sutton, Theresa A.; Guy, Hopkins; Cooper, Monte Cc: Dan Hampton; Robert Hawk; Annette Hurst; Gordon Katz; Kaufman, Daniel; Hornick, John; Sbauer; Joczek; Boutin, Anne; Esquenet, Margaret; Hart, Pat Subject: RE: ConnectU v. Facebook, Case No. 07-10593 DPW Dear Neel: We are currently considering the requests in your letter of July 2, 2007 (attached for your convenience). Your letter raises many issues we would like to discuss with our clients, but the Winklevoss brothers are out of the country, competing in the Pan America Games in Brazil. We do not expect to be able to have meaningful conversations with them until they return to the US late this month. Although we are willing to meet and confer before they return, our positions with respect to many of the production requests will be contingent on discussing them with our clients. Thus, we suggest waiting to meet and confer until after they return. Once we have discussed the issues raised by your letter with our clients, we will provide you with a letter detailing our position. If any issues remain which need further resolution, we can set up a discovery conference at that time. Please let us know if this is acceptable. Sincerely, Meredith

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10/24/2007