KELLEY DRYE &
WARREN LLP
333 WEST W
Case 5:03-cv-05340-JF Document 64 Filed 12/23/2005 Page 1 of 3
Google Inc. v. American Blind & Wallpaper Factory, Inc.
Doc. 64
Dockets.Justia.com
KELLEY DRYE &
WARREN LLP
333 WEST WACKER DRIVE
SUITE 2600
CHICAGO, IL 60606
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Case No. C03-5340 JF
Declaration of Caroline C. Plater ISO
Motion to Enforce Stipulated Protective Order
- 2 -
DM_US\8294100.v1
I, Caroline C. Plater declare as follows:
1.
I am an attorney at Kelley Drye & Warren LLP, counsel of record for
Defendant/Counter-Plaintiff American Blind & Wallpaper Factory, Inc. (“American Blind”) in
the above-captioned action. I am a member in good standing of the State Bar of Illinois. I have
personal knowledge of the facts set forth in this declaration and, if called as a witness, could and
would testify competently to such facts under oath.
2.
Attached hereto as Exhibit A is a true and correct copy of the Stipulated
Protective Order entered in this action.
3.
Attached hereto as Exhibit B are true and correct copies of documents
produced by Plaintiff/Counter-Defendant Google, Inc. (“Google”), with Bates Nos. GOOGLE
19971-19996.
4.
Attached hereto as Exhibit C are true and correct copies of documents
produced by Google with Bates Nos. GOOGLE 008990-008993.
5.
Attached hereto as Exhibit D are true and correct copies of documents
produced by Google with Bates Nos. GGE 005313-005314, 005443-005444, 005468-005469,
005531-005533, 005535-005537, 005549-005551, 005571-005572, 005579-005580, 005585-
005587, 005606-005607, 005670-005671.
6.
Attached hereto as Exhibit E are true and correct copies of documents
produced by Google with Bates Nos. GOOGLE 002717-002723.
7.
Attached hereto as Exhibit F is a true and correct copy of correspondence
from David A. Rammelt to Klaus Hamm, dated November 3, 2005.
8.
Attached hereto as Exhibit G is a true and correct copy of correspo