The opinion of the court was delivered by: Hon. Susan Illston United States District Judge
MELVIN R. GOLDMAN (CA SBN 34097) MGoldman@mofo.com STEPHEN P. FRECCERO (CA SBN 131093) SFreccero@mofo.com DEREK F. FORAN (CA SBN 224569) DForan@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522 7 Attorneys for Defendants Epson Imaging Devices Corporation and Epson Electronics America, Inc.
This Document Relates to:
STIPULATION AND [PROPOSED] ORDER 17 PERMITTING DEPOSITIONS BEYOND FACT DISCOVERY CUTOFF DATE
Plaintiff Motorola Mobility, Inc. ("Motorola") and Defendants Epson Imaging Devices Corporation and Epson Electronics America, Inc. (collectively "Epson"), parties to the above-3 entitled action (collectively, "Parties"), hereby stipulate as follows:
WHEREAS, the Parties have met and conferred to discuss scheduling the deposition of Motorola's employees Tracy Guo, C.F. Cheng, and C.M. Lai, and Epson employee Hiroyuki Matsuura;
WHEREAS, the aforementioned individuals are not available for deposition before the fact discovery cutoff date of December 8, 2011;
NOW, THEREFORE, the Parties, through their undersigned respective counsel, stipulate and request that the Court order as follows:
1. That the fact discovery cutoff date of December 8, 2011 be extended for the sole purpose of the aforementioned, proposed depositions; 11
2. That Defendants may take the deposition of Ms. Guo on December 14-15, Mr. Cheng on December 20, and Mr. Lai on December 21; 13
3. That Direct Action Plaintiffs may take the deposition of Mr. Matsuura at a date to be determined outside the fact discovery cutoff; and 15
4. That the Parties continue to work in good faith with regards to scheduling additional depositions of their respective employees after the close of fact discovery. To allow sufficient time for the Parties to coordinate with respect to any remaining depositions, the 17 deadline to move to compel further depositions of Motorola or Epson witnesses shall be extended 18 to January 31, 2012. 19 20
Attestation: The filer of this document attests that concurrence in the filing of this document has 10 been obtained from the other signatory.