Rockstar Consortium US LP et al v. Google Inc

Filing 164

Opposed MOTION for Hearing by Google Inc. (Attachments: # 1 Affidavit of Sam Stake, # 2 Exhibit 1, # 3 Text of Proposed Order Granting Google's Motion)(Perlson, David)

EXHIBIT 1

From:
Sent:
To:

Cc:
Subject:

Justin A. Nelson [[e-mail]]
Monday, September 22, 2014 10:39 AM
David Perlson; Shawn Blackburn; John Lahad; Cyndi Obuz; John Dolan; Max L. Tribble;
Parker Folse; Stacy Schulze; Tammie J. DeNio; '[e-mail]'; 'Elizabeth
DeRieux'; '[e-mail]'; '[e-mail]'; '[e-mail]'; Meng Xi;
Amanda Bonn
QE-Google-Rockstar; 'Mark Mann'; '[e-mail]'; 'Andy Tindel'
RE: October 9 Hearing

David – We do oppose because we believe it is up to the Court to add any topics to the hearing.
To the extent that the Court adds your motions, we would want our motions as well, but absent
direction from the Court we do not think it is appropriate to set additional items for a hearing on
a third party protective order. I am at my desk now if you would like to meet and confer by
phone.
Best Regards,
Justin A. Nelson
Susman Godfrey
1201 Third Avenue
Suite 3800
Seattle, WA 98101
206-516-3867
This message is intended only for the people to whom it is addressed and is intended to be a confidential
attorney-client communication. If this message is not addressed to you, please delete it and notify me.
From: David Perlson [mailto:[e-mail]]
Sent: Monday, September 22, 2014 10:23 AM
To: David Perlson; Shawn Blackburn; John Lahad; Justin A. Nelson; Cyndi Obuz; John Dolan; Max L. Tribble; Parker
Folse; Stacy Schulze; Tammie J. DeNio; '[e-mail]'; 'Elizabeth DeRieux'; '[e-mail]';
'[e-mail]'; '[e-mail]'; Meng Xi; Amanda Bonn
Cc: QE-Google-Rockstar; 'Mark Mann'; '[e-mail]'; 'Andy Tindel'
Subject: RE: October 9 Hearing

Following up my email from Friday. Can we please get Rockstar’s position? We would like to file our motion today so
please provide a time we can have a meet and confer on this today if Rockstar opposes.
Thanks,
David
From: David Perlson
Sent: Friday, September 19, 2014 11:30 AM
To: 'Shawn Blackburn'; 'John Lahad'; 'Justin A. Nelson'; 'Cyndi Obuz'; 'John Dolan'; 'Max L. Tribble'; 'Parker Folse'; 'Stacy
Schulze'; 'Tammie J. DeNio'; '[e-mail]'; 'Elizabeth DeRieux'; '[e-mail]';
'[e-mail]'; '[e-mail]'; 'Meng Xi'; 'Amanda Bonn'
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Cc: QE-Google-Rockstar; 'Mark Mann'; '[e-mail]'; 'Andy Tindel'
Subject: October 9 Hearing

Counsel,
Google intends to move pursuant to Local Rule CV-7(g) to set the following motions for hearing at the October
9 hearing already set on the Nortel Motions for Protective Order:
-

Google’s Motion To Transfer (Dkt. 18), Google’s Cross-Motion, in the Alternative, To Stay Pending
Resolution of Its Transfer Motion (Dkt. 97)
Google’s Motion for the Court To Enter Its Model Order (Dkt. 105)
Google’s Motion To Strike Plaintiffs’ Infringement Contentions (Dkt. 122)
Google’s Motion To Compel Complete Interrogatory Responses (Dkt. 136)

Please let us know if Plaintiff consents to this motion. If Plaintiff would like to add any of its pending motions to
a joint motion to set these matters for hearing that is acceptable to Google.
Please let us know your position. We would like to get the motion on file as soon as possible.
Thanks,
David

David Perlson
Partner,
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6344 Direct
415.875.6600 Main Office Number
415.875.6700 FAX
[e-mail]
www.quinnemanuel.com
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