Polaris IP, LLC v. Google Inc. et al

Filing 578

MOTION to Continue Trial and for Additional Time for Trial by Google Inc.. (Attachments: # 1 Affidavit Declaration of M. Kammerud, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order)(Perlson, David)

Polaris IP, LLC v. Google Inc. et al

Doc. 578 Att. 4

EXHIBIT C

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quinn emanuel

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January 6, 2009 VIA E-MAIL John J. Edmonds The Edmonds Law Firm 709 Sabine Street Houston, TX 77007 Re: Bright Response, LLC v. Google Inc, et al., 2:07-cv-371

Dear John: I write in response to your letter of December 27, in which you re-assert that Anthony Angotti has no documents responsive to Google's subpoena of November 13. In our December 19 correspondence to you, we requested a description of how the search for responsive documents was conducted. Your letter of December 27 did not address this request. Please provide a description of the document collection methods used in responding to the Anthony Angotti subpoena, including where and how you searched for responsive documents. If you are unwilling to provide this requested description, please explain your reasoning. As always, we remain willing to work with Plaintiff and third parties to resolve these and any other discovery issues. We hope that you similarly remain willing to meet and confer so that discovery can proceed in a timely and efficient manner. If you would prefer to discuss these issues by phone, please let me know your availability for a meet and confer.

quinn emanuel urquhart oliver & hedges, llp
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Best regards, /s/ Jennifer A. Kash
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