Righthaven LLC v. Democratic Underground, LLC et al
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)
Thursday, March 24, 2011 4:41 PM
Laurence Pulgram; Kurt Opsahl; Clifford Webb; 'Colby Williams'
Righthaven v. DU
You agreed that you would get back to us regarding Righthaven’s production of documents by March 2. We have still
not received any documents. Additionally, on March 3, you told us you would send the privilege log “shortly.” We have
not yet received a log either. We have not heard from you since March 3 regarding either Righthaven’s production of
documents or production of a privilege log. You continue to abuse the discovery process. If you have any intention to
comply with your discovery obligations, you have yet to demonstrate so.
JENNIFER J. JOHNSON
Fenwick & West LLP
Associate, Litigation Group
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