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Case 3:13-cv-00360-BEN-WMC Document 23 Filed 08/07/13 Page 1 of 3
`
`Joseph P. Reid (SBN 211082)
`Thomas N. Millikan (SBN 234430)
`Gartman Law Group P.C.
`11622 El Camino Real, Suite 100
`San Diego, California 92130
`Telephone: (858) 461-7360
`Attorneys for Plaintiff,
`ADVANCED AUCTIONS LLC
`Jared Bobrow (SBN: 133712)
`jared.bobrow@weil.com
`Andrew L. Perito (SBN: 269995)
`andrew.perito@weil.com
`Christopher S. Geyer (SBN: 288527)
`christopher.geyer@weil.com
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065-1134
`Telephone: (650) 802-3000
`Facsimile: (650) 802-3100
`Attorneys for Defendant,
`EBAY INC.
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
`Case No. 13cv360-BEN (WMc)
`JOINT MOTION TO MODIFY THE
`COURT’S MODEL ORDER
`GOVERNING ESI
`
`ADVANCED AUCTIONS LLC,
`
`
`
`Plaintiff,
`
`
`
`
`
`v.
`
`EBAY INC.,
`
`
`
`
`
`
`
`Defendant.
`
`Plaintiff Advanced Auctions LLC (“Plaintiff”) and Defendant eBay Inc.
`(“Defendant”) present this Joint Motion to Modify the Court’s Model Order
`Governing ESI in this case and related Case No. 13cv1612-BEN (WMc) as
`explained in the parties’ Joint Discovery and Case Management Plan. (Doc. No.
`22.) The parties have reached agreement on several modifications to the Court’s
`
`JOINT MOTION TO MOD. THE COURT’S
`MODEL ORDER GOVERNING ESI
`
`1
`
`Case No. 13cv360-BEN (WMc)
`
`1 2 3 4 5 6 7 8 9
`
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`

`

`Case 3:13-cv-00360-BEN-WMC Document 23 Filed 08/07/13 Page 2 of 3
`
`Model Order Governing ESI, but two disputes remain. The parties will lodge a
`Proposed Order Governing ESI, including their modifications and short statements
`summarizing the remaining disputes, via e-mail.
`NOW, THEREFORE, Plaintiff and Defendant jointly request and stipulate
`that the proposed Order Governing ESI lodged by email be entered as an order in
`both cases.
`
`DATED: August 7, 2013
`
`GARTMAN LAW GROUP, PC
`
`By:/s/ Thomas N. Millikan
`Joseph P. Reid (SBN 211082)
`Thomas N. Millikan (SBN 234430)
`Attorneys for Plaintiff
`ADVANCED AUCTIONS LLC
`
`DATED: August 7, 2013
`
`WEIL, GOTSHAL & MANGES LLP
`
`By:/s/ Andrew L. Perito
`Jared Bobrow (SBN 133712)
`Andrew L. Perito (SBN 269995)
`Christopher Geyer (SBN 288527)
`Attorneys for Defendant
`EBAY INC.
`
`JOINT MOTION TO MOD. THE COURT’S
`MODEL ORDER GOVERNING ESI
`
`-2-
`
` Case No. 13cv360-BEN (WMc)
`
`1 2 3 4 5 6 7 8 9
`
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`
`

`

`Case 3:13-cv-00360-BEN-WMC Document 23 Filed 08/07/13 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true and correct copy of the above
`and foregoing document has been served on August 7, 2013 to all counsel of
`record who are deemed to have consented to electronic service via the Court’s
`CM/ECF system per Civil Local Rule 5.4. Any other counsel of record will be
`served by electronic mail, facsimile and/or overnight delivery.
`
`/s/ Thomas N. Millikan
`Thomas N. Millikan
`Attorneys for Plaintiff
`Advanced Auctions LLC
`
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`
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`JOINT MOTION TO MOD. THE COURT’S
`MODEL ORDER GOVERNING ESI
`
`-3-
`
` Case No. 13cv360-BEN (WMc)
`
`

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