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 F

quinn emanuel

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July 23, 2009 VIA E-MAIL Ari Rafilson The Rafilson Law Firm, PLLC 1318 Royal Palm Lane Carollton, TX 75007 Re: PA Advisors v. Google Inc., et al.

Dear Ari: Wit h respect to the noticed deposition of Johanna Shelton, we consider the parties to have met and conferred on this in Dallas on Monday, July 20, 2009. However, we would appreciate a written explanation from PA Advisors as to why it believes a deposition of Ms. Shelton is necessary and what discoverable, relevant information she may have. We are not presently aware of any information that Ms. Shelton has that would bear upon this case. With respect to a motion for protective order, PA Advisors has noticed the deposition for July 31, which is the day defendants' claim construction brief is due. Please confirm that you will take the deposition off calendar for a week until August 7. Very truly yours, /s/ Andrea Pallios Roberts
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