Function Media, L.L.C. v. Google, Inc. et al

Filing 158

***REPLACES # 154 ***RESPONSE in Opposition re 153 Second MOTION to Expedite Motion to Compel filed by Google, Inc.. (Attachments: # 1 Affidavit in Support of Opposition to Function Media's Second Expedited Motion to Compel, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Text of Proposed Order)(Anderson, Carl) Modified on 8/24/2009 (ch, ).

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION FUNCTION MEDIA, L.L.C., v. JURY TRIAL DEMANDED GOOGLE, INC. AND YAHOO!, INC. DECLARATION OF BILLIE D. SALINAS IN SUPPORT OF GOOGLE INC.'S OPPOSITION TO FUNCTION MEDIA'S SECOND EXPEDITED MOTION TO COMPEL I, Billie D. Salinas, declare: I am an associate at Quinn Emanuel Urquhart Oliver & Hedges LLP, counsel for defendant Google, Inc. ("Google") in this litigation. The facts stated herein are true of my own personal knowledge and, if called as a witness, I could and would testify competently thereto. 1. Attached as Exhibit A is a true and correct copy of a June 11, 2009 E-mail from Civil Case No. 2:07-CV-279 (CE)

Justin A. Nelson to Jeremy Brandon. 2. Attached as Exhibit B is a true and correct copy of an August 3, 2009 E-mail from

Justin A. Nelson to Amy H. Candido. 3. Attached as Exhibit C is a true and correct copy of an August 4, 2009 Letter from

Amy H. Candido to Justin A. Nelson. 4. Attached as Exhibit D is a true and correct copy of an August 5, 2009 Letter from

Amy H. Candido to Justin A. Nelson. 5. Attached as Exhibit E is a true and correct copy of an August 14, 2009 Letter

from Amy H. Candido to Justin A. Nelson.

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6.

Attached as Exhibit F is a true and correct copy of an August 18, 2009 E-mail

from Justin A. Nelson to Amy H. Candido.

Dated: August 24, 2009

By: /s/ Billie D. Salinas

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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been served on all counsel of record via ECF/PACER this 24th day of August, 2009.

/s/ Billie D. Salinas Billie Salinas

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