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 X

Jennifer Johnson
From:
Sent:
To:
Cc:
Subject:

Jennifer Johnson
Thursday, March 03, 2011 10:05 AM
'[e-mail]'
'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
RE: Righthaven v. DU

Dear Shawn, 

I did not receive any discovery from you yesterday, as you had most recently promised.  Did I miss something?  Please 
advise as to the status of your supplemental responses, document production, and privilege log.   

Thanks,  
Jennifer 

JENNIFER J. JOHNSON
Fenwick & West LLP
Associate, Litigation Group
[phone]
[phone]
[e-mail]

From: [e-mail] [mailto:[e-mail]]
Sent: Friday, February 25, 2011 4:29 PM
To: Jennifer Johnson
Cc: 'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
Subject: RE: Righthaven v. DU

Jennifer:
I have been tied up with numerous matters (some Righthaven-related and some non-Righthaven-related), but I
am working on the issues we discussed. I am trying to have all of the issues addressed by Wednesday. I would
appreciate it if you can give me until then to have appropriate responses to you.
Regards,
S
Shawn A. Mangano, Esq.
Shawn A. Mangano, Ltd.
9960 West Cheyenne Avenue, Suite 170
Las Vegas, Nevada 89129
[phone] - telephone
[phone] - facsimile
Licensed in California, Nevada and Illinois

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-------- Original Message -------Subject: RE: Righthaven v. DU
From: Jennifer Johnson <[e-mail]>
Date: Fri, February 25, 2011 3:35 pm
To: "'[e-mail]'" <[e-mail]>
Cc: 'Kurt Opsahl' <[e-mail]>, Laurence Pulgram
<[e-mail]>, Clifford Webb <[e-mail]>, 'Colby
Williams' <[e-mail]>

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: '[e-mail]'
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
[phone]
[phone]
[e-mail]

From: Jennifer Johnson [mailto:[e-mail]]
Sent: Thursday, February 10, 2011 7:26 PM
To: '[e-mail]'
2

Cc: 'Kurt Opsahl'; Laurence Pulgram; Clifford Webb; 'Colby Williams'
Subject: Righthaven v. DU

Shawn,
Please see the attached correspondence summarizing our meet and confer.
Best,
Jennifer

JENNIFER J. JOHNSON
Fenwick & West LLP
Associate, Litigation Group
[phone]
[phone]
[e-mail]

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