Northeastern University et al v. Google, Inc.,

Filing 160

NOTICE by Google, Inc., re 127 Notice of Disclosure Objections to Plaintiffs' Pre-Trial Disclosures (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Duarte, Enrique)

Northeastern University et al v. Google, Inc.,

Doc. 160

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION NORTHEASTERN UNIVERSITY and JARG CORPORATION, Plaintiffs, v. GOOGLE INC., Defendant. GOOGLE'S OBJECTIONS TO PLAINTIFFS' PRE-TRIAL DISCLOSURES Pursuant to the Court's Discovery Order, dated Aug. 21, 2008 (D.I. 32), Google Inc. ("Google") hereby files and serves its objections to Jarg Corp. and Northeastern University's (collectively, "Plaintiffs") Deposition Designations and Exhibit List. Google generally objects to any deposition testimony designated by Plaintiffs, and to any document or exhibit identified on Plaintiffs' Exhibit List, that is the subject of the parties' agreed motion in limine or Google's motions in limine, motions to exclude certain evidence, Daubert motions and challenges to experts (if any), and any dispositive motions. Google reserves its right to make additional objections leading up to and at trial. Subject to the foregoing, Google objects to Plaintiffs' Deposition Designations as set forth in Attachment A, and objects to Plaintiffs' Exhibit List as set forth in Attachment B. The objection numbers in Attachment B refer to the corresponding Federal Rules of Evidence. Civil Action No. 2:07-CV-486- CE Jury Trial Demand

GOOGLE'S OBJECTIONS TO PLAINTIFFS' PRE-TRIAL DISCLOSURES - Page 1

Dockets.Justia.com

Dated: March 18, 2011

Respectfully submitted, FISH & RICHARDSON P.C. By: /s/ Enrique D. Duarte Jennifer Parker Ainsworth (SBN 00784720) [e-mail] WILSON, ROBERTSON &CORNELIUS, P.C. 909 ESE Loop 323, Suite 400 Tyler, TX 75701 Telephone: [phone] Facsimile: [phone] Michael E. Jones (SBN 10929400) [e-mail] POTTER MINTON 110 N. College, Suite 500 Tyler, TX 75702 Telephone: [phone] Facsimile: [phone] Ruffin B. Cordell (SBN 04820550) [e-mail] FISH & RICHARDSON P.C. 1425 K Street, N.W., 11th Floor Washington, DC 20005-3500 Telephone: [phone] Facsimile: [phone] Jason W. Wolff (CA SBN 215819) [e-mail] Frank Albert (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 12390 El Camino Real San Diego, CA 92130 Telephone: [phone] Facsimile: [phone] Jennifer N. Scarpati (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 601 Lexington Avenue, 52nd Floor New York, NY 10022-4611 Telephone: [phone] Facsimile: [phone]

GOOGLE'S OBJECTIONS TO PLAINTIFFS' PRE-TRIAL DISCLOSURES - Page 2

Howard G. Pollack (Admitted Pro Hac Vice) [e-mail] Shelley K. Mack (Admitted Pro Hac Vice) [e-mail] Jerry T. Yen (CA SBN 247988) [e-mail] Enrique D. Duarte (Admitted Pro Hac Vice) [e-mail] FISH & RICHARDSON P.C. 500 Arguello Street, Suite 500 Redwood City, CA 94063 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant GOOGLE INC.
50767152.doc

GOOGLE'S OBJECTIONS TO PLAINTIFFS' PRE-TRIAL DISCLOSURES - Page 3

CERTIFICATE OF SERVICE The undersigned hereby certifies that on March 18, 2011, a true and correct copy of the above and foregoing document was served on all counsel of record who are deemed to have consented to electronic service via the Court's CM/ECF system pursuant to Local Rule CV-5(a)(3). Any other counsel of record not deemed to have consented to electronic service were served by email and/or U.S. Mail on March 18, 2011. /s/ Enrique D. Duarte Enrique D. Duarte

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