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In Re Optical Disk Drive Products Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


January 8, 2013

IN RE OPTICAL DISK DRIVE PRODUCTS ANTITRUST LITIGATION

The opinion of the court was delivered by: Joseph C. Spero Judge

Jeff D. Friedman (173886) Shana E. Scarlett (217895) 2 HAGENS BERMAN SOBOL SHAPIRO LLP 715 Hearst Avenue, Suite 202 3 Berkeley, CA 94710 Telephone: (510) 725-3000 4 Facsimile: (510) 725-3001 jefff@hbsslaw.com 5 shanas@hbsslaw.com 6 Steve W. Berman (Pro Hac Vice) George W. Sampson (Pro Hac Vice) 7 HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 8 Seattle, WA 98101 Telephone: (206) 623-7292 9 Facsimile: (206) 623-0594 steve@hbsslaw.com 10 george@hbsslaw.com 11 Interim Lead Counsel for Indirect Purchaser Plaintiffs 12

[Additional Counsel Listed on 13 Signature Page] 14

STIPULATION BY INDIRECT PURCHASER PLAINTIFFS AND INTERVENOR UNITED STATES OF AMERICA REGARDING THE DEPOSITION OF WOO JIN ("EUGENE") YANG OF HLDS) DEFENDANT FAMILY

DATE ACTION FILED: Oct. 27, 2009

This Document Relates to:

ALL INDIRECT PURCHASER ACTIONS )) 26 27 28

WHEREAS on December 21, 2012, indirect purchaser plaintiffs filed an unopposed motion 2 requesting that this Court grant them leave to depose Woo Jin ("Eugene") Yang while Mr. Yang 3 was located at Lompoc prison in California; 4

WHEREAS the United States Department of Justice, Antitrust Division ("DOJ"), an 5 intervenor in this action, has requested that indirect purchaser plaintiffs postpone their deposition 6 of Mr. Yang for a period of time or DOJ would move the Court for an order delaying Mr. Yang's 7 testimony based on the nature of the DOJ's ongoing criminal antitrust investigation of the ODD 8 market; 9

IT IS HEREBY STIPULATED AND AGREED THAT:

1. Indirect purchaser plaintiffs' Unopposed Motion for Leave to Depose Woo Jin Yang (aka "Eugene Yang") in Lompoc Federal Correctional Institution, ECF No. 732, filed on December 12 21, 2012, requesting leave of Court to depose Mr. Yang while he is located at Lompoc federal 13 correctional institution is hereby withdrawn and the Court need take no further action; 14

2. The indirect purchaser plaintiffs will not seek the deposition of Mr. Yang for a 15 period of at least three months from the date of this stipulation, absent agreement with the DOJ; 16 and 17

3. Should the intervenor United States Department of Justice request the postponement 18 of the deposition of Mr. Yang beyond this three-month period, indirect purchaser plaintiffs will 19 consider this request in good faith. 20

IT IS SO STIPULATED.

IT IS SO ORDERED

CERTIFICATE OF SERVICE

I hereby certify that on January 7, 2013, I electronically filed the foregoing document using the CM/ECF system which will send notification of such filing to the e-mail addresses registered in 4 the CM/ECF system, as denoted on the Electronic Mail Notice List, and I hereby certify that I have 5 caused to be mailed a paper copy of the foregoing document via the United States Postal Service to 6 the non-CM/ECF participants indicated on the Manual Notice List generated by the CM/ECF 7 system. 8

Jeff D. Friedman

JEFF D. FRIEDMAN

20130108

© 1992-2013 VersusLaw Inc.



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