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In Re Intel Laptop Battery Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


March 9, 2011

IN RE INTEL LAPTOP BATTERY LITIGATION

The opinion of the court was delivered by: The Honorable James Ware United States District Judge

Geoffrey A. Munroe (State Bar No. 228590) Eric H. Gibbs (State Bar No. 178658) GIRARD GIBBS LLP U AS MODIFIED A 601 California Street, 14th Floor N San Francisco, California 94108 N James Ware R Telephone: (415) 981-4800 Facsimile: (415) 981-4846 Email: ehg@girardgibbs.com; gam@girardgibbs.com Plaintiff's Lead Counsel

(PSG)

STIPULATION AND [PROPOSED] ORDER

REGARDING DISCOVERY RESPONSES AND MOTIONS

Complaint Filed: June 26, 2009

Trial Date: None

Discovery Cutoff: February 28, 2011

hereby stipulate as follows:

Plaintiff Dart Seasonal Products, Inc. and First Set of Interrogatories to Plaintiff Dart Seasonal Products,

WHEREAS, Plaintiff requires additional time to respond to Intel's First Set of Document

Requests to Plaintiff Dart Seasonal Products, Inc. and First Set of Interrogatories to Plaintiff Dart

NOW THEREFORE, Plaintiff and Intel stipulate that:

Plaintiff will serve full and complete responses to Intel's First Set of Document Requests Nos. 3, 4, and 5, and produce any responsive documents, by March 18, 2011, and serve full and complete 12 responses to the remainder of the document requests and any responsive documents by April 4, 2011;

14 and 16 by March 18, 2011, and serve full and complete responses to the remainder of the interrogatories 15 by April 4, 2011;

Intel will have up through and including April 11, 2011 to file a discovery motion, if necessary, regarding Plaintiff's responses to Intel's First Set of Document Requests and First Set of Interrogatories 18 to Plaintiff Dart Seasonal Products, Inc.

Dated: February 28, 2011 GIRARD GIBBS LLP

Plaintiff Dart Seasonal Products, Inc. ("Plaintiff") and Defendant Intel Corporation ("Intel")

WHEREAS, the deadline for Plaintiff to respond to Intel's First Set of Document Requests to Inc. is February 28, 2011 and the court-ordered close of discovery is also on February 28, 2011; and Seasonal Products, Inc.;

Plaintiffs will serve full and complete responses to Intel's First Set of Interrogatories Nos. 14, 15,

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Plaintiff will serve full and complete responses to Intel's First Set of Document Requests Nos. 3, 4, and 5, and produce any responsive documents, by March 18, 2011, and serve full and complete 5 responses to the remainder of the document requests and any responsive documents by April 4, 2011; 6

Plaintiff will serve full and complete responses to Intel's First Set of Interrogatories Nos. 14, 15, and 16 by March 18, 2011, and serve full and complete responses to the remainder of the interrogatories 8 by April 4, 2011;

Intel will have up through and including April 11, 2011 to file a discovery motion regarding Plaintiff's responses to Intel's First Set of Document Requests and First Set of Interrogatories to Plaintiff Dart Seasonal Products, Inc.

This Stipulation shall not modify any other deadlines set in the Court's Case Schedule.

DATED: ____________________, 2011

March

March 928,

20110309

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