[PROPOSED] ORDER REGARDING DEPOSITION OF DEFENDANT OKI ELECTRIC INDUSTRY CO., LTD. PURSUANT TO FED. R. CIV. P. 30(B)(6) AT THE UNITED STATES EMBASSY, TOKYO JAPAN
HOWARD R. LLOYD, District Judge.
TO ANY CONSUL OR VICE-CONSUL OF THE UNITED STATES ASSIGNED TO TOKYO, JAPAN:
WHEREAS, the above-captioned civil lawsuit has been pending before this Court since July 2012;
WHEREAS, the Plaintiffs NavCom Technology, Inc. and Deere & Company allege breach of contract by Defendant Oki Electric Industry Co., Ltd.;
WHEREAS, discovery began in November 2012;
WHEREAS, Plaintiffs have reserved a deposition room at the United States Embassy in Tokyo, Japan for taking depositions from September 9-10, 2013;
On stipulation of Parties, and pursuant to Article 17 of the United States-Japan Consular Convention of 1963, 15 U.S.T. 768,
IT IS ORDERED that the depositions of the following witnesses, who will appear voluntarily, be taken at the United States Embassy in Tokyo, Japan:
Name: Yoko Goto
Employer: Oki Electric Industry Co., Ltd.
Address: 1-7-12 Toranomon Minato-ku Tokyo 105-8460, Japan Deposition of the above individual will commence on or about September 9, 2013 at 8:30 a.m. (local time) and conclude on or about September 10, 2013, at 5:00 p.m. (local time).
Counsel for Plaintiffs who will participate in said depositions include one or more of the following: Brett M. Schuman, Ryan L. Scher and Rachel M. Walsh.
Counsel for Defendant who will participate in said depositions include one or more of the following: Marc R. Labgold, Patrick J. Hoeffner, Takaaki Nagashima and Yuichiro Yasutomo.
In addition to counsel for Plaintiffs, Navcom and/or Deere & Co. corporate representatives ...