Performance Pricing, Inc. v. Google Inc. et al

Filing 241

MOTION to Compel Production of Documents by Third Parties Neal Cohen and Vista IP Law Group, LLP by AOL LLC, Google Inc.. (Attachments: # 1 Joint Stipulation Regarding Defendant Google Inc. and AOL LLC's Motion to Compel Production of Documents by Third Parties Neal Cohen and Vista IP Law Group, LLP, # 2 Declaration of Emily C. O'Brien in Support of Motion to Compel, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18 Exhibit P, # 19 Declaration of Christin Cho in Opposition to Motion to Compel, # 20 Errata 1, # 21 Exhibit 2, # 22 Exhibit 3, # 23 Proposed Order Granting Defendant Google Inc. and AOL LLC's Motion to Compel)(O'Brien, Emily) Modified on 9/25/2009 (sm, ). Modified on 9/25/2009 (sm, ).

Performance Pricing, Inc. v. Google Inc. et al
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Doc. 241

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1 QUINN EMANUEL UR^UHART OLIVER & HEDGES, LLP
Charles K. Verhoeven ( ar No. 170151}

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charlesverhoeven quinnemanuel.com David A. Perlson^ar No. 209502) david erlson@ u^nnemanuel.com Jennifer A . Kas (Bar No . 203679) ^}[e-mail] 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: [phone] Facsimile: ^4 i 5^ 875-6704

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Attorneys for Defendant Google Inc. and 8 AOL LLC 9 UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

PERFORMANCE PRICING, INC., 13 Plaintiff, 14 vs. 15 GOGGLE INC. and AOL LLC, 16 Defendants. 17 18 19

CASE NO.:

CV09 -62$3 GAF {CTx}

DISCOVERY MATTER DEFENDANT GOGGLE INC. AND AOL LLC' S NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY THIRD PARTIES NEAL COHEN AND VISTA IP LAW GROUP LLC Crtrm.: ^^^^^. ^^^

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01002 . 513053031662.2

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Hrg. Date: ^ (a^ f at}0 ^ Hrg. Time: ^ ; ^0 ^^

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DEFENDANT GOGGLE INC. AND AOL LLC'S ivlOT10N TO CONfPEL ckets.Justia.com Do PRODUCTION

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on
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3 soon thereafter as this matter can be heard before the Honorable 4 of the United States District Court for the Central District of California, at 411 West S Fourth Street, Santa Ana, CA 92701-4516, Defendants Google Inc. and AOL LLC 6 ("Defendants"} will and hereby do move to compel the production of documents by 7 third parties Neal Cohen and Vista IP Law Group, LLP ("Cohen"}. 8 The parties have met and conferred in good faith in an attempt to resolve this

9 dispute as required by Local Rule 37-1. See generally Declaration of Emily C. 10 OBrien. 11 This Motion is related to Performance Pricing, Inc. v. Google Inc. et al., Case

12 No. 2:07-cv-432 (LED}, currently pending in the Eastern District of Texas. i3 Discovery closes on November 13, 2009. The pretrial conference is set for March 14 18, 20 i 0. Trial begins on April 12, 2010. 1S This Motion is based on this Notice of Motion, the Joint Stipulation of the

16 parties pursuant to Local Rule 37-2, the Declaration of Emily C. O'Brien, the 17 exhibits thereto, and upon such oral argument and submissions that may be 18 presented at or before the hearing on this Motion. 19 20 DATED: August 25, 2009 21 22 23 24 25 26^^ 27 28
O1002.S130S13031662.2 -L,__

Respectfully submitted,

QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP

BY

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David A. Perlson C^yj Attorneys for Defendant Google Inc. and AOL LLC

DEFENDANT GOOGLE INC. AND AOL LLC's MO"ClON TO COMPEL PRODUC"C10N