I/P Engine, Inc. v. AOL, Inc. et al

Filing 180

Declaration re 179 Opposition, of Jennifer Ghaussy in Support of Defendants' Opposition to Plaintiff's Motion for Leave to Take 30(b)(1) Depositions by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Noona, Stephen)

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EXHIBIT L DICKSTEINSHAPIROLLP 1825 Eye Street NW I Washington, DC 20006-5403 (202) 420-2200 I FAX (202) 420-2201 I dicksteinshapiro.com TEL June 19, 2012 Via E-mail Emily C. O'Brien, Esq. Quinn Emanuel Urquhart & Sullivan, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Re: 30(b)(1) Deposition Count Dear Emily: Further to the Court's order and Judge Stillman's advice on Friday that the parties resolve this issue, we write to propose a solution to the issue of the number of 30(b)(1) depositions in this case. With respect to 30(b)(1) depositions, we propose that I/P Engine take a number of fact depositions for each Defendant that is equal to the number of individuals listed in the respective initial disclosures for that Defendant. This would be a total of 14 individual fact witness depositions: 3 for Google, 5 for AOL, 2 for Gannett, 3 for JAC, and 1 for Target. Please advise whether Defendants agree to this proposal. Please also reconfirm that Mr. Derek Cook is being made available for deposition and the date. Best rpgards, terio, Jr. Charles J. (202) 420-516 MonterioC@dicksteinshapiro.com CJM/ cc: Stephen E. Noona David Bilsker Kenneth W. Brothers Jeffiey K. Sherwood Dawn Rudenko Albert Los Angeles I New York I Orange County I Silicon Valley I Stamford I Washington, DC DSMDB-3071398

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