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 F

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

[e-mail]
Friday, January 21, 2011 4:01 PM
Jennifer Johnson
Laurence Pulgram; 'Kurt Opsahl'
RE: Righthaven LLC v. Democratic Underground

Jennifer:
I know the first part of next week is really tight with other client matters aside from the Righthaven-related
actions. I will get back to you with some available times for a meet and confer on the RFA responses.
With regard to the interrogatory and request for production responses, Righthaven was handling their service. If
they did not go out electronically, then they may have only gone out via U.S. Mail. I know they were prepared
by me and provided to Righthaven to print out and serve.
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
-------- Original Message -------Subject: Righthaven LLC v. Democratic Underground
From: "Jennifer Johnson" <[e-mail]>
Date: Fri, January 21, 2011 2:50 pm
To: <[e-mail]>
Cc: "Laurence Pulgram" <[e-mail]>, "'Kurt Opsahl'"
<[e-mail]>

Dear Shawn,
We are in receipt of Righthaven’s responses to DU’s First Set of Requests for
Admission, and we would like to set up a time to meet and confer regarding the
inadequacy of Righthaven’s responses. We note at the outset that Righthaven
provided only objections and no response to 78 of the 82 Requests for
Admission. We would like to confer no later than January 26, so please provide
your availability.
Additionally, we would like to receive by January 26: (1) the documents
responsive to DU’s First Set of Requests for Production of Documents and (2)
responses to DU’s First Set of Interrogatories. Righthaven has waived all
objections to these discovery requests by not timely responding in any fashion. If
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you are not prepared to provide that information by January 26, we should
include this subject in our meet and confer session as well.
Please notify us as to when you are available to meet and confer.
Regards,
Jennifer

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

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