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

Filing 979

Memorandum in Support re 978 MOTION for Order to Show Cause UNDER RULE 37 FOR NONCOMPLIANCE WITH AUGUST 13, 2013 ORDER filed by I/P Engine, Inc.. (Attachments: # 1 Exhibit A)(Sherwood, Jeffrey)

Exhibit A

Monterio, Charles
From:
Sent:
To:
Cc:
Subject:

Margaret P. Kammerud <[e-mail]>
Wednesday, August 28, 2013 10:40 PM
Monterio, Charles; zz-IPEngine; Brothers, Kenneth
QE-IP Engine; '[e-mail]'; '[e-mail]'; '[e-mail]'
I/P Engine v. Google

Counsel:
As discussed in our meet and confer yesterday, Google maintains that its custodial emails are not relevant. Google
already produced technical documents and made the source code available for your inspection in compliance with the
Court’s Order. In any event, in order to work with Plaintiff in good faith to avoid unnecessary disputes, Google will do a
targeted production of email. Google is in the process of identifying custodians and search terms. We will provide
additional information later this week regarding the timing of the production.
Regards,
Meg
Margaret P. Kammerud
Associate,

Quinn Emanuel Urquhart & Sullivan, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
415-875-6316 Direct
415.875.6600 Main Office Number
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www.quinnemanuel.com
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