CNG Financial Corporation v. Google Inc

Filing 41

RESPONSE to Motion re 38 MOTION to Compel The Production of Documents filed by Plaintiff CNG Financial Corporation, Counter Defendant CNG Financial Corporation. (Attachments: # 1 Exhibit A - CNG's website home page# 2 Exhibit B - sample search page generated by a Google search# 3 Exhibit C - CNG's Financial Corporation's Response to the Motion by Google to Compel the Production of Documents# 4 Declaration of Barry D. Hunter in Support of CNG Financial Corporation's Response to the Motion by Google to Compel the Production of Documents# 5 December 1, 2006 correspondence from Barry D. Hunter to Eugene M. Paige, Esq.)(Hunter, Barry)

CNG Financial Corporation v. Google Inc

Case 1:06-cv-00040-SSB-TSB

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Doc. 41 Att. 5

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Document 41-6

Filed 01/08/2007

Page 1 of 1

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ATTORNEYS
KENTUCKY' OHIO' INDIANA' TENNESSEE

Barry D. Hunter
[phone]
8HUNTER~F8TLAW,COM

December 1,2006

VIA E-MAIL AND

U.S.

MAIL

Eugene M. Paige, Esq. Keker & Van Nest LLP 710 Sansome Street San Francisco, CA 94107
Re: CNG Financial Corp. v. Google, Inc.

Dear Eugene:
This is to ,acknowledge my receipt, today, of the November 27, 2006

letter that you faxed

to my office here in Kentucky on that date. As you undoubtedly know from your discussions

with your colleagues, Michael Page and Klaus Hamm, I was not in my office on Monday, November 27, or on November 28, 29 or 30 - - having been spending those days taking
depositions with Michael and Klaus in Mountain View, California.

I note that your letter requests that I respond by December 1, i.e., today. While I will endeavor to address the issues you raised in your letter as soon as practical next week, I will not be able to meet your deadline. In the future, if you require my attention on an immediate basis at a time when I am in depositions with Michael and Klaus, have Michael or Klaus hand me the
letter.

I look forward to responding to your concerns next week.
Very truly yours,

(l r;żunt r
BDH:prl
LEXLibrary 0102393,0533475 319299v.l

250 West Main Street, Suite 2700

Lexington, Kentucky 40507-1749

[phone]' [phone] fax

ww.frostbrowntodd.com

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