Righthaven LLC v. Democratic Underground, LLC et al
Filing
96
DECLARATION of CLIFFORD C. WEBB In Support of Defendant Democratic Underground, LLC's First Motion to Compel the Production of Documents re 95 First MOTION to Compel the Production of Documents By Defendant Democratic Underground, LLC and Memorandum of Points and Authorities In Support Thereof ; filed by Defendants David Allen, Democratic Underground, LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27 Exhibit AA, # 28 Exhibit BB, # 29 Exhibit CC, # 30 Exhibit DD, # 31 Exhibit EE, # 32 Exhibit FF)(Webb, Cliff)
EXHIBIT U
Jennifer Johnson
From:
Sent:
To:
Cc:
Subject:
Jennifer Johnson
Friday, February 25, 2011 3:35 PM
'shawn@manganolaw.com'
'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
RE: Righthaven v. DU
Shawn,
We have still not received supplemental discovery responses from Righthaven. We have also not received any
documents from Righthaven, or a privilege log. You agreed to have us a privilege log and non‐confidential documents by
today. You agreed to produce confidential documents 7‐10 days after entry of the protective order. 10 days was
yesterday. We expect to hear back from you today as to when we will be receiving this information.
Regards,
Jennifer
From: Jennifer Johnson
Sent: Wednesday, February 23, 2011 1:51 PM
To: 'shawn@manganolaw.com'
Cc: 'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
Subject: RE: Righthaven v. DU
Shawn,
I’m following up on your promise to have us supplemental responses 10 days after our meet and confer. We have not
yet received them. Please serve by email, per our agreement.
Thanks,
Jennifer
JENNIFER J. JOHNSON
Fenwick & West LLP
Associate, Litigation Group
(415) 875-2391
(415) 281-1350
jjjohnson@fenwick.com
From: Jennifer Johnson [mailto:jjjohnson@fenwick.com]
Sent: Thursday, February 10, 2011 7:26 PM
To: 'shawn@manganolaw.com'
Cc: 'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
Subject: Righthaven v. DU
Shawn,
Please see the attached correspondence summarizing our meet and confer.
1
Best,
Jennifer
JENNIFER J. JOHNSON
Fenwick & West LLP
Associate, Litigation Group
(415) 875-2391
(415) 281-1350
jjjohnson@fenwick.com
2
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