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

Filing 288

DECLARATION re #287 Opposition to Motion by Facebook, Inc.. (Attachments: #1 Exhibit A - Notice of Manual Filing, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G - Notice of Manual Filing)(Sutton, Theresa)

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

Doc. 288 Att. 3

EXHIBIT C

Dockets.Justia.com

Page 1 of 1

Dalton, Amy
Subject: FW: Quinn v Winklevoss -- Case No 13 194 Y 995 08

From: Thompson, Karen Sent: Thursday, September 17, 2009 5:03 PM To: [e-mail]; [e-mail]; [e-mail] Cc: Jonathan Weed ([e-mail]); Chatterjee, I. Neel; Sutton, Theresa A. Subject: Quinn v Winklevoss -- Case No 13 194 Y 995 08 Dear Messrs. Drier, Jackson and Silberberg: On behalf of Non-Party Facebook, I write to request that the subpoena duces tecum issued to Facebook, Inc. on September 11, 2009 be withdrawn. The documents requested, to the extent that they exist, contain private, internal and confidential information that belongs to Facebook. To the extent that such valuations exist, the Respondents-Counterclaimants have never seen, received, or relied upon the documents; most certainly not within the course of Settlement Agreement negotiations with Facebook. The requested documents cannot be claimed as material to the instant arbitration between Quinn Emanuel and the Respondents-Counterclaimants. Respondents-Counterclaimants' subpoena is another attempt to avoid the discovery order of the Northern District of California and to gain access to the work product of unretained experts. Accordingly, Facebook respectfully requests that the Respondents-Counterclaimants withdraw the September 11 subpoena. We note that this request for withdrawal does not constitute a waiver of the Non-Party's rights to pursue any and all objections in a court of competent jurisdiction and all such rights are expressly reserved. Best Regards, Karen Thompson

KAREN D. THOMPSON Associate ORRICK, HERRINGTON & SUTCLIFFE LLP 666 FIFTH AVENUE NEW YORK, NY 10103-0001 tel [phone] fax [phone] [e-mail] www.orrick.com

10/6/2009