UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
January 17, 2012
ROBIN ANTONICK, AN ILLINOIS CITIZEN,
ELECTRONIC ARTS INC., A CALIFORNIA CORPORATION, DEFENDANT.
The opinion of the court was delivered by: Magistrate Judge Elizabeth D. Laporte Northern District of California
HAGENS BERMAN SOBOL SHAPIRO LLP Robert B. Carey (Pro Hac Vice) 2 Leonard W. Aragon (Pro Hac Vice) 3 11 West Jefferson Street, Suite 1000 Phoenix, Arizona 85003 4 Telephone: (602) 840-5900 Facsimile: (602) 840-3012 5 Email: email@example.com firstname.lastname@example.org 6 7 THE PAYNTER LAW FIRM PLLC Stuart M. Paynter (226147) 8 Jennifer L. Murray (Pro Hac Vice) 1200 G Street N.W., Suite 800 9 Washington, DC 20005 Telephone: (202) 626-4486 10 Facsimile: (866) 734-0622 11 email@example.com Attorneys for Plaintiff Robin Antonick 13 14
STIPULATION AND [PROPOSED] ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF'S MOTION TO COMPEL
WHEREAS on January 10, 2012, the Court held hearing on Plaintiff's December 2, 2011
Motion to Compel; 3
4 interrogatories; 5
6 submit a stipulation and proposed order memorializing the Court's rulings; 7
8 order; 9
IT IS HEREBY ORDERED that
Defendant shall produce all source code, source code documentation and development 11 materials in its possession for any John Madden Football or Madden NFL videogame that is listed 12 in its Fourth Amended Response to Interrogatory No. 1 and was released on or before January 1, 13 For any versions for which Defendant does not produce source code, Defendant's Counsel 15 shall certify in writing that a diligent search was conducted and that the source code cannot be 16 found; 17
January 6, 2012 Motion to Compel based on Plaintiff's analysis to date; 20 21 withdrawn without prejudice to re-file following Plaintiff's service of the amended interrogatory 22 responses described above. Plaintiff shall not move to compel any additional source code for any 23 title released after January 1, 1996 prior to the service of the amended interrogatory responses 24 described above; 25
WHEREAS on January 6, 2012, Defendant filed a motion to compel responses to certain
WHEREAS the Court having considered the papers and argument requested that the parties
WHEREAS the parties have met and conferred and agreed to the entry of this proposed
Within ninety (90) days of receiving a complete production in response to this order, Plaintiff shall prepare and serve amended responses to the interrogatories subject to Defendant's 19
IT IS FURTHER ORDERED that Defendant's January 6, 2012 Motion to Compel is hereby
IT IS FURTHER ORDERED that Defendant shall provide an amended response to Interrogatory No. 3 that describes in detail the approaches, methods, safeguards, and processes 27 used to ensure independent development of any John Madden Football or Madden NFL videogame 28 listed therein, which was released on or before January 1, 1996. Such amended response shall be 2 served within FOURTEEN (14) days of the entry of this order. 3
IT IS FURTHER ORDERED that Defendant shall produce all documents in response to Plaintiff's Request for Production No. 12 that relate to the approaches, methods, safeguards, and 5 processes used to ensure independent development of any John Madden Football or Madden NFL 6 videogame listed therein, which was released on or before January 1, 1996. Such documents shall 7 be served within FOURTEEN (14) days of the entry of this order 8 Pursuant to General Order No. 45 section 10(b), R. Adam Lauridsen, the filer of this 9 stipulation hereby attests that Stuart M. Paynter concurs in the filing of this stipulation.
IT IS SO ORDERED.
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