Polaris IP, LLC v. Google Inc. et al

Filing 224

RESPONSE in Opposition re 222 MOTION for Protective Order Modification AND REQUEST FOR EMERGENCY HEARING, IF NECESSARY filed by Bright Response LLC. (Attachments: # 1 Affidavit of Andrew D. Weiss, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Weiss, Andrew)

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Polaris IP, LLC v. Google Inc. et al Doc. 224 Att. 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC v. GOOGLE, INC., et al. NO. 2:07-CV-371-CE JURY DECLARATION OF ANDREW D. WEISS IN SUPPORT OF BRIGHT REPONSE, LLC'S RESPONSE TO YAHOO!, INC.'S MOTION TO MODIFY PROTECTIVE ORDER I, Andrew D. Weiss, declare and state as follows: 1. I am a member of the State Bar of California and an associate at the firm of Russ, August & Kabat, counsel of record for Plaintiff Bright Response, LLC in the above-captioned action. I have personal knowledge of the facts set forth herein, and if called upon to testify, could and would testify competently thereto. 2. The letters attached in support of Bright Response, LLC's Response to Yahoo's Motion to Modify the Protective Order are true and correct copies of correspondence maintained in files regarding this matter: a. Exhibit A is a true and correct copy of a September 24, 2009 letter sent by counsel for plaintiff to counsel for defendant in PA Advisors, LLC v. Google, Inc., Case No. 2:07-cv-480-DF (E.D. Tex.). b. Exhibit B is a true and correct copy of a September 17, 2009 letter from counsel for Bright Response to counsel for Yahoo. c. Exhibit C is a true and correct copy of an email and attached sent by counsel for Bright Response to counsel for Yahoo on November 5, 2009. 2995-011 091109 ADW Decl ISO Resp Mod PO.doc 1 Dockets.Justia.com I declare under penalty of perjury pursuant to the laws of the United States that the foregoing is true and correct. Executed this 9th day of November, 2009 at Los Angeles, California By: /s/ Andrew D. Weiss Andrew D. Weiss 2

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