I/P Engine, Inc. v. AOL, Inc. et al
Filing
1005
Declaration re 1003 Opposition, (of Joshua L. Sohn) in Support of Defendants' Opposition to Plaintiff's Motion for Leave to File Supplemental Memorandum Regarding Motion to Show Cause and Motion to Strike Plaintiff's Supplemental Memorandum by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Noona, Stephen)
EXHIBIT 2
Joshua Sohn
From:
Sent:
To:
Cc:
Subject:
Attachments:
Emily O'Brien
Thursday, March 29, 2012 12:47 PM
Monterio, Charles
zz-IPEngine; QE-IP Engine; Noona, Stephen E.
I/P Engine
4655316_1_3.28.2012 Proposed Stipulation.doc; 4510860_6_Proposed ESI Agreement 3 28
12.doc
Charles, please find attached our current proposed stipulation regarding discovery. Given that the parties have not
been able to reach agreement regarding the language regarding contentions, we have removed that language entirely
from the stipulation.
Additionally, I have discussed the proposed ESI Agreement with the team. Given that the parties have agreed to
language regarding voicemail and IM, we do not feel it is necessary or appropriate to investigate this issue further with
our client. If this becomes an issue in the future, we can discuss at that time.
There is one addition we would like to make to the ESI Agreement. We have added in redline a sentence stating that the
parties agree that only sent and received custodial emails will be searched. Please let us know if Plaintiff is agreeable to
this revision, and if we now have final agreement on the ESI and discovery stipulations.
Thank you,
Emily
Emily O'Brien
Associate,
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6323 Direct
415.875.6600 Main Office Number
415.875.6700 FAX
emilyobrien@quinnemanuel.com
www.quinnemanuel.com
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