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 W

DICKSTEINSHAPIROLLP
1825 Eye Street NW I Washington, DC 20006-5403
[phone] I FAX [phone] I dicksteinshapiro.com

TEL

April 26, 2012
Via E-mail
David Perlson, Esq.
Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Re:

Target's, Gannett's and IAC's Objections to I/P Engine's 30(b)(6) Notices of Deposition

Dear David:
1/P Engine received Target's, Gannett's and IAC's (collectively "Defendants") objections to I/P Engine's
30(b)(6) Notices of Deposition. As we have advised you, I/P Engine considers Defendants' objections
and responses untimely; under Local Rule 26, any objection to discovery requests must be served within
15 days after service. I/P Engine notes that Defendants' objections to I/P Engine's Liability and Damages
30(b)(6) Notices are the same. Please distinguish between record objections, and objections on which
Defendants intend to rely upon to substantively limit the testimony of its designees.
With respect to I/P Engine's Liability 30(b)(6) Notice, it appears that Defendants intend to not produce a
corporate designee in response to topics 8-17. Regarding I/P Engine's Damages 30(bX6) Notice, it
appears that Defendants intend to not produce a corporate designee in response to topics 4-11. We will
confirm this apparent impasse during today's meet and confer.
We intend to proceed with these depositions before Google's 30(b)(6) deposition, and on the liability
issues first. We intend to confirm during today's meet and confer that Defendants' refusal to designate
any witnesses on any topics has created an impasse.
Best regards,
Charles J. Mo en
‘1002) 420-5167
[e-mail]
CJM/
cc:

Stephen E. Noona
David Bilsker
Kenneth W. Brothers
Jeffrey K. Sherwood
DeAnna Allen

Los Angeles I New York I Orange County I Silicon Valley I Stamford I Washington, DC
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