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)
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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