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

Filing 148

AFFIDAVIT of Monte M.F. Cooper in Support re #146 MOTION to Compel Response to Interrogatory No. 1 filed by Dustin Moskovitz, Andrew McCollum, Christopher Hughes, Thefacebook LLC, Facebook, Inc., Mark Zuckerberg. (Attachments: #1 Exhibit 1#2 Exhibit 2#3 Exhibit 3#4 Exhibit 4#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)(Cooper, Monte)

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

Doc. 148 Att. 14

Case 1:07-cv-10593-DPW

Document 148-15

Filed 11/14/2007

Page 1 of 2

EXHIBIT 14

Dockets.Justia.com

F
rom: Sent: To: Cc: Adam Wolfson [[e-mail]] Sunday, October 14, 2007 7:07 PM Cooper, Monte; Sutton, Theresa A. Mudurian, Karen; Dalton, Amy; Chatterjee, I. Neel; Guy, Hopkins; Annette Hurst; Dan Hampton; Sbauer; Joczek; Boutin, Anne; Hanhan, Melinda; Day, Chester; Trinh, Michael; Greer, Yvonne; Stillman, Stacey; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; Rick Werder; Peter Calamari; Renee Bea; Sarah Hartley

Subject: RE: Response to September 6, 2007 Cooper Letter Monte, Can you please explain which alleged deficiencies in our prior Interrogatory Responses remain deficient in light of the FAC and the current state of discovery? As noted in my prior email, Neel Chatterjee's letter actually explaining the alleged deficiencies -- the only such explanation of which we are aware -- was sent before we filed our amended pleading. As such, that letter could not contemplate the facts alleged in the FAC itself. Also, I will point out that your previous correspondence on the interrogatories occurred prior to the September 13th hearing. As you will remember, the Court granted access to Defendants' hard drives as well as required Defendants to locate relevant code central to the various causes of action on previously produced CDs. Since Plaintiffs have not been able to view the hard drive images yet, and Defendants stated that they did not believe they were required to go the expense of providing court-ordered information, we have not received any further information which could even potentially supplement contention interrogatories. Regards, Adam Wolfson Quinn Emanuel Urquhart Oliver & Hedges, LLP 51 Madison Avenue, 22nd Floor New York, NY 10010 Direct: [phone] Main Phone: [phone] Main Fax: [phone] E-mail: [e-mail] Web: www.quinnemanuel.com The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message.