Page 1 PageID#
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
DEFENDANT GOOGLE LLC’S MOTION FOR ENTRY OF ORDER
REGARDING COORDINATION OF DISCOVERY
1.
Defendant Google LLC (“Google”), through its undersigned counsel, hereby
respectfully moves for the entry of an Order Regarding Coordination of Discovery in the abovecaptioned action. The grounds for the motion are as follows:
2.
As the Court is aware, a multi-district litigation with substantial legal and factual
similarities to this case is currently pending in the U.S. District Court for the Southern District of
New York, under docket number 1:21-md-3010-PKC (the “MDL”).
3.
As referenced in the joint motion for entry of a protective order (ECF No. 96), the
parties in this case have met and conferred regarding a proposed order allowing for coordination
of discovery between this case and the MDL, to further the interests of judicial efficiency and
reduce the burden on party and non-party witnesses. Through that process, the parties have
prepared the proposed Order Regarding Coordination of Discovery (“Coordination Order”)
attached as Exhibit A.
4.
The Coordination Order reflects the parties’ agreements on many issues, and it
identifies, as the parties’ competing proposals, some areas where they do not agree. One area
where the parties agree is that the proposed order should not take effect unless and until it is
entered in this case and in the MDL. See Ex. A ¶ 10.Page 2 PageID#
5.
For the reasons explained in Google’s accompanying Brief Supporting
Coordination Order, Google respectfully requests that the Court adopt Google’s proposed
language in the Coordination Order and then enter the Order.
Dated: April 28, Respectfully submitted,
FOR DEFENDANT GOOGLE LLC:
/s/ Tyler Garrett
Eric Mahr (pro hac vice)
Andrew J. Ewalt (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street NW, 10th Floor
Washington, DC Telephone: (202) 777-Facsimile: (202) 777-Email: eric.mahr@freshfields.com
Craig C. Reilly (VSB # 20942)
209 Madison Street
Alexandria, VA Telephone: (703) 549-Facsimile: (703) 549-Email: craig.reilly@ccreillylaw.com
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 165 Filed 04/28/23 Page 1 of 2 PageID# 1248
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
DEFENDANT GOOGLE LLC’S MOTION FOR ENTRY OF ORDER
REGARDING COORDINATION OF DISCOVERY
1.
Defendant Google LLC (“Google”), through its undersigned counsel, hereby
respectfully moves for the entry of an Order Regarding Coordination of Discovery in the abovecaptioned action. The grounds for the motion are as follows:
2.
As the Court is aware, a multi-district litigation with substantial legal and factual
similarities to this case is currently pending in the U.S. District Court for the Southern District of
New York, under docket number 1:21-md-3010-PKC (the “MDL”).
3.
As referenced in the joint motion for entry of a protective order (ECF No. 96), the
parties in this case have met and conferred regarding a proposed order allowing for coordination
of discovery between this case and the MDL, to further the interests of judicial efficiency and
reduce the burden on party and non-party witnesses. Through that process, the parties have
prepared the proposed Order Regarding Coordination of Discovery (“Coordination Order”)
attached as Exhibit A.
4.
The Coordination Order reflects the parties’ agreements on many issues, and it
identifies, as the parties’ competing proposals, some areas where they do not agree. One area
where the parties agree is that the proposed order should not take effect unless and until it is
entered in this case and in the MDL. See Ex. A ¶ 10.
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 165 Filed 04/28/23 Page 2 of 2 PageID# 1249
5.
For the reasons explained in Google’s accompanying Brief Supporting
Coordination Order, Google respectfully requests that the Court adopt Google’s proposed
language in the Coordination Order and then enter the Order.
Dated: April 28, 2023
Respectfully submitted,
FOR DEFENDANT GOOGLE LLC:
/s/ Tyler Garrett
Eric Mahr (pro hac vice)
Andrew J. Ewalt (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street NW, 10th Floor
Washington, DC 20005
Telephone: (202) 777-4500
Facsimile: (202) 777-4555
Email: eric.mahr@freshfields.com
Craig C. Reilly (VSB # 20942)
209 Madison Street
Alexandria, VA 22314
Telephone: (703) 549-5354
Facsimile: (703) 549-5355
Email: craig.reilly@ccreillylaw.com
2
Back to 
