July 31, 2013
NAVCOM TECHNOLOGY, INC.; AND DEERE & COMPANY, Plaintiffs,
OKI ELECTRIC INDUSTRY CO., LTD.; and DOES 1 through 10, inclusive, Defendants.
[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 Patricia Harris will attend.
In addition to the deponents and counsel for Defendants, Oki corporate representatives Mr. Isao Goto and Ms. Mikiko Higashino will also attend.
The proceedings will be reported by Karen Claire Young, Cynthia Renee Ott, Robert Vance Short, Leslie Anne Todd, Susan Dena Wasilewski, Melanie Louise Giamarco, Deborah Ruth Marshall, Lisa A. Knight, Tracy LoCastro, James Vernon Beasley, Jodi Beth Harmon and/or Keith Shreckengast. The proceedings will be recorded on video by Paul B. Diserio, Paul Michael Goldberg and/or Daniel Dean of Legal Video Asia. Grace Liu, Toyu Yazaki and/or William Lise will act as interpreters.
The transcripts of the deposition will be prepared and distributed among the interested parties by the court reporter without further involvement by the United States Embassy
The parties respectfully request that the Court provide five certified copies of the Order pursuant to these stipulations, to be mailed by Parties' counsel to the United States Embassy in Tokyo, Japan.
IT IS SO ORDERED.