NetJumper Sofware L. L. C. v. Google, Incorporated

Filing 87

MOTION to Take Deposition from Randall Stark by Google, Incorporated. (Attachments: # 1 Index of Exhibits # 2 Exhibit 1: 1st Supp. Init. Disc. Statement of Google# 3 Exhibit 2: Google's Witness List# 4 Exhibit 3: Letter to Hamameh from Wolff (July 8, 2006)# 5 Exhibit 4: Notice of Depo. of Randall Stark# 6 Exhibit 5: E-mail to Hamameh from Rosen (July 12, 2006)# 7 Exhibit 6: E-mail to Wolff from Hamameh (July 20, 2006))(Wolff, Jason)

NetJumper Sofware L. L. C. v. Google, Incorporated

Doc. 87 Att. 7

Case 2:04-cv-70366-JAC-RSW

Document 87-8

Filed 07/24/2006

Page 1 of 2

EXHIBIT 6

Dockets.Justia.com

Case 2:04-cv-70366-JAC-RSW

Document 87-8

Filed 07/24/2006

Page 1 of 1 Page 2 of 2

Jason Wolff
From: Sent: To: Hamameh, Nabeel N [[e-mail]] Thursday, July 20, 2006 11:02 AM Jason Wolff

Subject: Netjumper/Google Jason, This email will confirm that you granted us a one-week extension to file a response to your Markman brief, and our response is now due on July 31. We should enter into a stipulation as to this agreement, and I will forward one on Monday for your review. As for the remainder of depositions, we would like to have Galler's deposition taken on August 18, if possible, because Andy will be in Texas on other cases until August 17. We would like to schedule Luna's deposition in the latter half of August if possible, and Phil Green in the last week of August. We can work with Hardin on August 22. With respect to Stark, I was under the presumption that he is an expert witness, but he did not submit an expert report. If he is a fact witness, please advise whether discovery is still open because we were under the impression that fact discovery was closed. If fact discovery is still open based on your estimation, then there are several more individuals that we would like to depose. Do you plan on presenting his deposition testimony in lieu of trial testimony? Please advise. Thank you for your attention to these matters. Regards, Nabeel

7/24/2006