PA Advisors, LLC v. Google Inc. et al

Filing 257

MOTION to Quash and, MOTION for Protective Order to Preclude Deposition of Johanna Shelton by Google Inc.. (Attachments: #1 Affidavit Declaration of Brian Cannon, #2 Exhibit A to Declaration of Brian Cannon, #3 Exhibit B to Declaration of Brian Cannon, #4 Exhibit C to Declaration of Brian Cannon, #5 Exhibit D to Declaration of Brian Cannon, #6 Exhibit E to Declaration of Brian Cannon, #7 Exhibit F to Declaration of Brian Cannon, #8 Exhibit G to Declaration of Brian Cannon, #9 Exhibit H to Declaration of Brian Cannon, #10 Exhibit I to Declaration of Brian Cannon, #11 Exhibit J to Declaration of Brian Cannon, #12 Exhibit K to Declaration of Brian Cannon, #13 Exhibit L to Declaration of Brian Cannon, #14 Affidavit Declaration of Johanna Shelton, #15 Text of Proposed Order)(Cannon, Brian)

EXHIBIT E

From: Sent: T o: Cc: Subject:

David Pridham [[e-mail]] Monday, July 20, 2009 1:26 PM Michael Richardson; A Spangler Jason White; Marc Fenster; PA Advisors v. Google; Patrick Anderson; Ari Rafilson RE: nXn v. Google

Michael, For clarity, nXn agreed to delay the date of the Shelton deposition until after claim construction briefing (nXn did not agree to withdraw the deposition notice). nXn still requires a date for the Shelton deposition. As discussed, nXn would prefer to conduct this deposition when it is taking other depositions in this case in early / mid August. nXn is willing to work with Google to schedule this deposition but it is not willing to wait for weeks on end only to have Google file another motion for PO. Please let us know Google's position as to the specific issues we discussed as soon as possible. Best, David
From: Michael Richardson [mailto:[e-mail]] Sent: Monday, July 20, 2009 3:10 PM To: A Spangler Cc: David Pridham; Jason White; Marc Fenster; [e-mail]; Patrick Anderson; Ari Rafilson Subject: RE: nXn v. Google Andrew: Based on our conversation this morning, this will confirm that Plaintiff has agreed to withdraw the Shelton deposition notice until after claim construction briefing is completed. Thanks. Michael -----Original Message----From: Ari Rafilson [mailto:[e-mail]] Sent: Friday, July 17, 2009 12:50 PM To: Brian Cannon Cc: 'A Spangler'; David Pridham ([e-mail]); Jason White; Marc Fenster; Michael Richardson; [e-mail]; Patrick Anderson Subject: nXn v. Google

Brian, Attached is a subpoena for Ms. Johanna Shelton. If for some reason Ms. Shelton or defendants' counsel is unavailable on July 31, 2009, please propose alternate dates near this date. Best Regards, Ari Rafilson The Rafilson Law Firm, PLLC 1318 Royal Palm Lane Carrollton, TX 75007 Tel. [phone] Fax. [phone] [e-mail]
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