`
`One Newark Center, 19th Floor
`Newark, New Jersey 07102
`
` Tel: 973.690.5400 Fax: 973.466.2761
`www.rwmlegal.com
`
`
`
`January 19, 2016
`
`
`
`Via ECF
`
`The Honorable Michael A. Hammer, U.S.M.J.
`United States District Court for the District of New Jersey
`Martin Luther King Building & U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07101
`
`Re: WAG Acquisitions L.L.C. v. Sobonito Investments. Ltd., et al. (14-cv-01661);
`WAG Acquisitions L.L.C. v. MultiMedia, LLC, et al. (14-cv-02340);
`WAG Acquisitions L.L.C. v. WMM LLC, et al. (14-cv-02345);
`WAG Acquisitions L.L.C. v. Flying Crocodile, et al., (14-cv-02674);
`WAG Acquisitions L.L.C. v. Gattyan Group S.a.r.l et al. (14-cv-02832);
`WAG Acquisitions L.L.C. v. FriendFinder Networks Inc., et al. (14-cv-03456);
`WAG Acquisitions L.L.C. v. Vubeology, Inc., et al. (14-cv-04531); and
`WAG Acquisitions L.L.C. v. WebPower, Inc., et al. (15-cv-03581)
`
`Dear Judge Hammer,
`
`On behalf of Plaintiff WAG Acquisition, L.L.C. (“WAG”) and the Defendants in the
`above-captioned cases (“Defendants”) (collectively, “the Parties”), we write regarding the Court’s
`Letter Orders (e.g., D.I. 66 in 14-cv-02340).
`
`The parties have met and conferred to prepare the required submissions for the January 22
`Rule 16 conference, namely: the Joint Discovery Plan; E-Discovery Order; and 502(d) Order. The
`Parties are filing these documents with the Court today.1
`
`Where the Parties were unable to reach agreement in the Joint Discovery Plan, we have
`included competing proposals, respectively titled “Plaintiff’s Position” and “Defendants’
`Position.” The Parties have no disagreements concerning the E-Discovery and 502(d) Orders.
`
`We appreciate the Court’s courtesies and consideration. We look forward to meeting with
`
`the Court on January 22, 2016 at 11:00 AM, during which the Parties will be ready to address the
`foregoing and any other matters Your Honor may have.
`
`Respectfully,
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`s/ Justin T. Quinn
`Justin T. Quinn
`
`All counsel of record (via ECF)
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`cc:
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`1 The Parties will continue to meet and confer on a Confidentiality Order to submit to the Court
`by February 8, 2016.
`
`
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