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`Case 5:18-md-02834-BLF Document 489-3 Filed 08/16/19 Page 1 of 2
`
`
`
`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`RAVI R. RANGANATH (CSB No. 272981)
`rranganath@fenwick.com
`CHIEH TUNG (CSB No. 318963)
`ctung@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Counsel for AMAZON.COM, INC. and
`AMAZON WEB SERVICES, INC.
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`IN RE PERSONAL WEB TECHNOLOGIES,
`Case No.: 5:18-md-02834-BLF-SVK
`LLC, ET AL., PATENT LITIGATION
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICES, INC.,
`
`v.
`PERSONALWEB TECHNOLOGIES, LLC
`and LEVEL 3 COMMUNICATIONS, LLC,
`
`Defendants.
`
`PERSONALWEB TECHNOLOGIES, LLC
`and LEVEL 3 COMMUNICATIONS, LLC,
`Counterclaimants,
`
`Plaintiffs,
`
`Case No.: 5:18-cv-00767-BLF-SVK
`[PROPOSED] ORDER GRANTING
`RELIEF REQUESTED IN JOINT
`STATEMENT ON MOTION BY
`AMAZON.COM, INC. AND AMAZON
`WEB SERVICES, INC. TO COMPEL
`PERSONALWEB TO RESPOND TO
`INTERROGATORIES AND PRODUCE
`DOCUMENTS
`Discovery Cut-Off: August 16, 2019
`
`
`
`v.
`AMAZON.COM, INC., and AMAZON WEB
`SERVICES, INC.,
`Counterdefendants.
`
`
`
`
`[PROPOSED] ORDER GRANTING RELIEF
`REQUESTED IN JOINT STATEMENT RE MOTION TO
`COMPEL BY AMAZON
`
`
`
`
`
`
`CASE NO: 5:18-MD-02834-BLF-SVK
`CASE NO: 5:18-CV-00767-BLF-SVK
`
`
`
`
`
`Case 5:18-md-02834-BLF Document 489-3 Filed 08/16/19 Page 2 of 2
`
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`[PROPOSED ORDER]
`Having considered the joint statement on the motion by Amazon.com, Inc. and Amazon Web
`Services, Inc. (“Amazon”) to compel PersonalWeb to provide interrogatory responses and produce
`documents, IT IS HEREBY ORDERED THAT all relief requested by Amazon.com, Inc. and Amazon
`Web Services, Inc. (collectively “Amazon”) in the joint statement is hereby GRANTED, and the
`Court hereby ORDERS as follows:
`(1)
`PersonalWeb shall respond fully to Amazon’s Interrogatory Nos. 11-14 by providing a
`complete narrative response, including identifying all responsive contentions and
`supporting facts, within seven (7) days of this order;
`PersonalWeb shall produce all documents responsive to Amazon’s RFP Nos. 94 and
`95 within seven (7) days of this order;
`To the extent it maintains any claim of common interest privilege with respect to any
`documents responsive to RFP Nos. 94-95, PersonalWeb shall provide a log of all
`withheld documents with a description of its basis for assertion of the privilege within
`fourteen (14) days of this order;
`Amazon shall raise any issues regarding compliance with this order within thirty (30)
`days.
`IT IS SO ORDERED.
`
`(2)
`
`(3)
`
`(4)
`
`Dated: _______________________
`
`
`
`Honorable Susan van Keulen
`United States Magistrate Judge
`
`
`
`
`
`[PROPOSED] ORDER GRANTING RELIEF
`REQUESTED IN JOINT STATEMENT RE MOTION TO
`COMPEL BY AMAZON
`
`2
`
`
`
`
`CASE NO: 5:18-MD-02834-BLF-SVK
`CASE NO: 5:18-CV-00767-BLF-SVK
`
`
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