EMG Technology, LLC v. Apple, Inc.

Filing 206

RESPONSE in Opposition re 199 MOTION to Vacate 100 Order, 99 Order The Deadlines In The Docket Control And Discovery Orders And For A Case Management Conference MOTION to Vacate 100 Order, 99 Order The Deadlines In The Docket Control And Discovery Orders And For A Case Management Conference filed by EMG Technology, LLC. (Attachments: # 1 Affidavit Hansen, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K)(Ainsworth, Charles)

EMG Technology, LLC v. Apple, Inc.

Doc. 206 Att. 9

Exhibit H to the Declaration Of Shawn G. Hansen In Support Of Plaintiff EMG Technology, LLC's Response In Opposition To Apple Inc.'s Motion To Vacate The Deadlines In The Docket Control And Discovery Orders And For A Case Management Conference

Dockets.Justia.com

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Hansen, Shawn
From: Sent: To: Cc: John Lane [[e-mail]] Friday, December 18, 2009 7:57 AM Hansen, Shawn Garland Stephens; David Healey

Subject: RE: EMG v. Apple - Apple's Failure to Comply with Paragraph 2.C.iv. of the Discovery Order

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John, Apple's production of emails pursuant to Paragraph 2.C.iv. of the Discovery Order now is long overdue. On June 30, 2009, Stan provided key words for searching that limit the amount of email to a reasonable amount. Apple was to produce emails within one hundred and twenty (120) days, or by October 28, 2009. Please provide a date certain when Apple will comply with its obligation to produce emails in compliance with Paragraph 2.C.iv. of the Discovery Order. To the extent Apple would like to discuss possible modification of the key word list, please let me know the volume of emails responsive to the June 30, 2009, list so we have a sense of how much modification of the list may be appropriate. In addition, I have received no response to my email of October 27, 2009, requesting emails from Wayne Westerman. Please confirm that Apple will comply with that request and provide a date certain when the emails of Mr. Westerman will be produced. Thank you, Shawn G. Hansen Partner manatt | phelps | phillips 1001 Page Mill Road, Building 2 Palo Alto, CA 94304 650.812.1367 - direct 650.812.1300 - main 650.814.1607 - mobile [phone] - direct fax Albany | Los Angeles | New York | Orange County | Palo Alto | Sacramento | San Francisco | Washington, D.C. Click here to see my profile Please conserve resources by not printing this email unnecessarily.

12/30/2009

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12/30/2009