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 M
Jen Ghaussy
From:
Sent:
To:
Cc:
Subject:
Emily O'Brien
Thursday, June 21, 2012 6:51 PM
Monterio, Charles
zz-IPEngine; QE-IP Engine; Stephen E. Noona; Alexander, Cortney; Burns, Robert
I/P Engine v. AOL et. al. 6-19-12 Letter from C. Monterio to E. O'Brien
Charles,
I write to follow up on our call today regarding the number of depositions of Defendants in the I/P Engine case.
As discussed on our call and in our correspondence below, we do not see Plaintiff’s most recent proposal as a
compromise. Instead, it is a reiteration of Plaintiff’s prior proposal that we rejected recently and earlier in this
case, before the parties reached agreement on depositions of the Defendants. Our clients, as we have said,
would prefer to go forward with the parties’ original agreement on the number of depositions and the identity of
the witnesses. You stated that if the Defendants insist on this agreement, then Plaintiff will go forward with a
motion on Monday.
During our call, you and I both indicated that our clients may be willing to compromise, if possible. In order to
know if a compromise is possible, we need to know specifically what Plaintiff wants regarding its depositions
of the Defendants. Can Plaintiff identify the individual witnesses it wishes to take from each Defendant,
including those that are not listed in the Defendants’ Initial Disclosures? Will Plaintiff agree to a smaller
number of depositions from each Defendant than in its last proposal, and if so what is that number? These are
the same types of specifics that the Court has indicated it will want to know in trying to resolve this issue. Also,
if you can provide a more specific compromise proposal, we will consider it with our clients and see if the
parties can reach a reasonable new agreement.
As we previously discussed, I’m generally available tomorrow via telephone for further conference.
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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From: Jen Ghaussy
Sent: Tuesday, June 19, 2012 5:36 PM
To: Monterio, Charles
Cc: zz-IPEngine; QE-IP Engine; Stephen E. Noona
Subject: RE: I/P Engine v. AOL et. al. 6-19-12 Letter from C. Monterio to E. O'Brien
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Charles, rather than propose a compromise, Plaintiff’s letter simply repeats the same position that it has taken
previously. This is not productive. We have rejected this proposal in the past, including before the parties
entered into the operative agreement. We would be happy to consider an actual compromise proposal from
Plaintiff. In the meantime, Google will continue to operate under the terms of the parties’ agreement, under
which Plaintiff is not permitted to take Derek Cook’s deposition.
Best,
Jen
From: Chagnon, Armands [mailto:ChagnonA@dicksteinshapiro.com]
Sent: Tuesday, June 19, 2012 10:43 AM
To: QE-IP Engine; senoona@kaufcan.com
Cc: zz-IPEngine
Subject: I/P Engine v. AOL et. al. 6-19-12 Letter from C. Monterio to E. O'Brien
Counsel,
Please see the attached correspondence.
Regards,
Armands
Armands Chagnon | Senior Paralegal
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW | Washington, DC 20006
Tel (202) 420-3511 | Fax (202) 420-2201
ChagnonA@dicksteinshapiro.com
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