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SURREPLY RE MOTION TO STAGE
DISCOVERY
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P. CRAIG CARDON, Cal. Bar No. 168646
BRIAN R. BLACKMAN, Cal. Bar No. 196996
KENDALL M. BURTON, Cal. Bar No. 228720
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
Four Embarcadero Center, 17th Floor
San Francisco, California 94111-4106
Telephone:
415-434-9100
Facsimile:
415-434-3947
TIMOTHY H. KRATZ (Admitted Pro Hac Vice)
LUKE ANDERSON (Admitted Pro Hac Vice)
MCGUIRE WOODS, L.L.P
1170 Peachtree Street, N.E., Suite 2100
Atlanta, Georgia 30309
Telephone: 404.443.5500
Facsimile: 404.443.5751
Attorneys for DIGITAL ENVOY, INC.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
DIGITAL ENVOY, INC.,
Plaintiff/Counterdefendant,
v.
GOOGLE, INC.,
Defendant/Counterclaimant.
Case No. C 04 01497 RS
DIGITAL ENVOY, INC.’S SURREPLY RE
GOOGLE, INC.’S MOTION TO STAGE
DISCOVERY
Digital Envoy submits this further memorandum in opposition to Google's Motion for
Protective Order Staging Discovery in order to address the following limited issues pertinent
thereto, which were raised by Google subsequent to Digital Envoy's Opposition being submitted.
As described in Digital Envoy’s prior brief, Google submitted extensive discovery to
Digital Envoy timed such that Digital Envoy’s responses were served before Google filed this
motion. Portions of the discovery requests whose scope were far beyond the contemplated first
stage of discovery were quoted in Digital Envoy’s memorandum. Digital Envoy has expended the
effort to respond to those requests as required by rule.
Case 5:04-cv-01497-RS Document 34 Filed 08/23/2004 Page 1 of 3
Digital Envoy Inc., v. Google Inc.,
Doc. 34
Dockets.Justia.com
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