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)

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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 NOTICE: The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 1

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