I/P Engine, Inc. v. AOL, Inc. et al
Filing
209
MOTION to Compel Plaintiff To Produce Documents by Google Inc.. (Attachments: # 1 Exhibit 1)(Noona, Stephen)
Exhibit 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
I/P ENGINE, INC.,
Plaintiff,
v.
Civil Action No. 2:11-cv-512
AOL INC., et al.,
Defendants.
[PROPOSED] ORDER TO COMPEL PLAINTIFF TO PRODUCE DOCUMENTS
On this day came Defendant Google, Inc. ("Google"), by counsel, upon the Motion to
Compel Plaintiff I/P Engine Inc. (“Plaintiff”) to Produce Documents, and, upon consideration of
the arguments set forth in the Notice, and for good cause shown, it is
ORDERED that Plaintiff, within five (5) days of the entry of this order, shall produce the
following documents:
1. all documents provided by Innovate/Protect, Inc. to potential investors that concern
the patents-in-suit and this litigation;
2. the consulting agreement between Dickstein Shapiro LLP ("Dickstein Shapiro") and
Donald Kosak;
3. all documents of Andrew K. Lang responsive to Google’s requests for production; and
4. all documents related to Dickstein Shapiro's pre-litigation involvement in offers to sell
the patents-in-suit, negotiations related to the patents-in-suit, and the actual sale of the
patents-in-suit from Lycos, Inc. to Plaintiff.
It is FURTHER ORDERED that, within five (5) days of the entry of this order, to the
extent that any of Mr. Lang’s documents responsive to Google’s requests for production
have not been maintained or no longer exist, Plaintiff shall provide an explanation for
their destruction.
Dated: August _____, 2012
Entered:
_____/_____/_____
F. Bradford Stillman, Magistrate Judge
United States District Court
Eastern District of Virginia
WE ASK FOR THIS:
By: /s/ Stephen E. Noona
Stephen E. Noona
KAUFMAN & CANOLES, P.C.
150 West Main Street
Post Office Box 3037
Norfolk, VA 23514
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
Telephone: (415) 875-6600
Facsimile: (415) 875-6700
Counsel for Defendant GOOGLE INC.
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