Google v. Pacific Webworks

Filing 27

MOTION to Quash Subpoena filed by Movant www.goog-money-tree.com. and Movant www.googlemoneyprofitsystems.com (Christiansen, Gregory) Modified on 1/26/2010 to add www.googlemoneyprofitsystems.com as movant (jmr).

Blair R. Jackson (10170) CHRISTIANSEN & JACKSON, PC 10421 South Jordan Gateway, Suite 600 South Jordan, Utah 84095 Telephone: [phone] Facsimile: [phone]

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

In re: www.goog-money-tree.com, and www.google moneyprofitsystem.com

WWW.GOOG-MONEY-TREE.COM'S, and WWW.GOOGLEMONEYPROFIT SYSTEM.COM'S MOTION TO QUASH SUBPOENA

_______________________________________ Case No.: 2:09-CV-01068 GOOGLE, INC. Judge Bruce S. Jenkins Plaintiff v. PACIFIC WEBWORKS, INC. Defendant Owner of domains www.goog-money-tree.com and www.googlemoneyprofitsystem.com (hereinafter "Domain Owner"), by and through its attorney of record, files this Motion to Quash Subpoena pursuant to Federal Rules of Civil Procedure, Rule 45(c)(3)(i), (iii), and (iv). The Subpoena should be quashed as Domain Owner has not seen the subpoena and two (2) days is insufficient time to determine what response Domain Owner should allow of its

information. Further, Domain Owner has not been able to determine what privileged or other protected matter is being demanded. Finally, the subpoena is requesting information for which Domain Owner is financially obligated to pay, notwithstanding the fact it has no interest Google's action against Pacific Webworks, Inc. A Memorandum in Support of this motion is filed herewith. DATED this _25th_ day of January, 2010. s/ Blair R. Jackson__________________ Blair R. Jackson Attorney for Domain Owner

CERTIFICATE OF SERVICE BY MAIL, HAND DELIVERY OR FACSIMILE TRANSMISSION I hereby certify that a true and correct copy of the foregoing document was on this date served upon the persons named below, at the addresses set out below their name, either by mailing, hand delivery or by telecopying to them a true and correct copy of said document in a properly addressed envelope in the United States mail, postage prepaid; by hand delivery to them; or by facsimile transmission. Blaine J Benard Holme Roberts & Owen, LLP 299 S Main Street, Suite 1800 Salt Lake City, Utah 84111 Katherine Keating, Esq. Holme Roberts & Owen, LLP 560 Mission St., 25th Floor San Francisco, CA 94105 Alan L. Sullivan Robert E. Mansfield Snell & Wilmer 15 W South Temple Suite 1200 Salt Lake City, Utah 84101 Jeffery M. Lillywhite 12176 Pine Valley Way Draper, Utah 84020 GoDaddy.Com C. Lovetro Compliance Manager 480-624-2546 Facsimile DATED this 25 day of January, 2010 s/ Blair R. Jackson Blair R. Jackson [ x ] Mail [ ] Facsimile [ x ] Electronic Notice Delivery [ x ] Mail [ ] Facsimile [ x ] Electronic Notice Delivery

[ x ] Mail [ ] Facsimile [ x ] Electronic Notice Delivery [ x ] Mail [ ] Facsimile [ x ] Electronic Notice Delivery [ x ] Mail [ ] Facsimile [ ] Hand Delivery