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

Doc. 241 Att. 19

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Gregory S. Dowel (SB No. 135387) [e-mail] Christin Cho (SB No. 235173} [e-mail] DOVEL & LUNER, LLP 201 Santa Monica Blvd., Suite 600 Santa Monica, California 90401 {310) 656-7066 "[phone] fax

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8' Attorneys for Neal Cohen 9 10 11 12 '^ 13' 14 1S I6 17 18 19 20 21 22 23 24 25 26 27 28 .fudge: Defendants. Hearing: vs.
Declaration of Christin Cho in sucpport

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA PERFORMANCE PRICING, 1NC., Plaintiff, Discovery Matter

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GOOGLE INC. and AOL LLC,

of Cohen ' s Opposition to Defendants' lVlotion to Compel

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C, Christin Cho, declare:
1_ I am an associate with Dovel & Luner LLI', counsel for Neal Cohen.

This declaration is submitted in support of Cohen's apposition to defendants' rnotion to compel production of documents. The matters referred to in this declaration are

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based upon my personal knowledge, and if called as a witness C could testify ^ competently as to those matters. 2. Attached as Exhibit 1 is a true and correct copy of excerpts from the

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deposition of Neal Cohen, which took place on February 1 I, 2049. 3_ On .Tuly 13, 2408, an Agreed Protective Order was entered in this case-

Attached as Exhibit 2 is a true and correct copy of the Agreed Protective Order_ 4. Wayne Lin and his company, FricePlay, have produced documents and

privilege logs in this litigation- Attached as Exhibit 3 is a true and correct copy of the; privilege log served by Wayne Lin and Pricel'iay on May 29, 2009.

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C declare, under penalty of per^un^ under the laws of the United States, that the

21 ^ foregoing is true and accurate.

Executed in Santa Monica, California, on August 17, 2049. Isl Christin Cho · ^, ^^^'^

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