Free Declaration in Support - District Court of California - California

Case 3:07-cv-05086-WHA

Document 68-22

Filed 09/11/2008

Page 1 of 2 Page 1 of 2

Van Voorhis, Kimberly N.
From: Sent: To: Cc: George Prince [[email protected]] Friday, June 13, 2008 2:48 PM Van Voorhis, Kimberly N. Lontayao, Loraine

Subject: RE: letter of June 13, 2008 This is an accurate reflection, Kim. Thank you. >>> "Van Voorhis, Kimberly N." 6/13/2008 2:28 PM >>> George, As a follow up to our call today, defendants expect to serve their answer the week of June 23rd. I am estimating that a 30-day extension of fact/expert discovery will be sufficient, but we will need to see the answer before confirming this. Also, you have agreed that plaintiffs' first set of requests for admission and first set of interrogatories, served yesterday, are timely and that plaintiff will provide substantive responses when they are due. I will review the case schedule and, to the extent a stipulation is necessary, I will prepare it for your review. Please let me know right away if this does not reflect your understanding. Thanks, Kim

Kimberly Van Voorhis
Morrison & Foerster 755 Page Mill Road Palo Alto, CA 94304 650-813-4262 tel 650-494-0792 fax [email protected] www.mofo.com

From: George Prince [mailto:[email protected]] Sent: Friday, June 13, 2008 12:25 PM To: Van Voorhis, Kimberly N. Subject: letter of June 13, 2008 Hello Kim, We have received your letter of today, and I have conferred with DSS as to it. Defendants appreciate your offer of compromise and will agree to extend fact and expert discovery by a reasonable time to allow plaintiffs to conduct discovery relevant to the answer. If defendants were to get their answer on file by July 3rd, how much time after that would you expect to need to complete discovery? Please let me know.

9/10/2008

Case 3:07-cv-05086-WHA

Document 68-22

Filed 09/11/2008

Page 2 of 2 Page 2 of 2

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CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

9/10/2008