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 F

quinn emanuel

trial lawyers | san francisco

50 California Street, 22nd Floor, San Francisco, California 94111-4788 | TEL: [phone] FAX: [phone]

May 23, 2012

Charles Monterio
[e-mail]

Re:

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

Dear Charles:
I write in response to your letter of May 22, 2012 regarding Plaintiff’s Notice of Deposition to
Derek Cook. You state that the parties previously discussed “fourteen aggregate 30(b)(1)
depositions of Defendants.” As noted in my letter of May 16, the parties had agreed to “the right
to depose each fact witness affiliated with a defendant and who has been disclosed pursuant to
Rule 26(a).” It was those specific, previously disclosed, fourteen witnesses that Defendants
agreed to have deposed in their individual capacity.
While we are willing to consider individual depositions of different employees of the
Defendants, including your requested deposition of Mr. Cook, we need to discuss Plaintiff’s
intentions with respect to future depositions. For example, does Plaintiff no longer intend to take
fact depositions of some or all of the witnesses listed in Google’s initial disclosures (or that of
other defendants)? Is Plaintiff at this time aware of other employees of Defendants that Plaintiff
intends to notice for deposition? As I’m sure you can understand, we want to be sure that if we
agree to the deposition of Mr. Cook we are not opening a Pandora’s Box regarding depositions
of the defendants beyond what was agreed.
We are not available to meet and confer on May 24 at 4 PM ET, but would be available at 4 PM
ET on Friday, May 25. Please let us know if this date and time would work for you.

quinn emanuel urquhart & sullivan, llp
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538-8100

Sincerely,

Jen Ghaussy
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