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Case 5:05-cv-00334-RMW
1 2 3 4 5 6 7
Document 2313
Filed 09/29/2008
Page 1 of 2
ROBERT E. FREITAS (STATE BAR NO. 80948) CRAIG R. KAUFMAN (STATE BAR NO. 159458) VICKIE L. FEEMAN (STATE BAR NO. 177487) THERESA E. NORTON (STATE BAR NO. 193530) ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401 Attorneys for Defendants and Counterclaim Plaintiffs NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION U.S.A.
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN JOSE DIVISION
11 RAMBUS INC.,
Case No. CV-05-00334 RMW
12 Plaintiff, 13 v. 14 15 16 17 18 19 20 21 22
HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA, INC., HYNIX SEMICONDUCTOR MANUFACTURING AMERICA INC., SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P.,
DECLARATION OF THERESA E. NORTON IN SUPPORT OF NANYA TECHNOLOGY CORPORATION AND NANYA TECHNOLOGY CORPORATION USA’S REPLY TO RAMBUS’ OPPOSITION TO THE MOTION RE-OPEN DISCOVERY AS TO CERTAIN DEPOSITIONS Date: Time: Location: Judge:
October 1, 2008 8:30 a.m. Telephonic Hearing Hon. Read A. Ambler (Ret.)
NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants.
23 24
AND RELATED ACTIONS.
25 26 27 28 NORTON DECLARATION RE NANYA’S MOTION TO RE-OPEN DISCOVERY CASE NO. C05-00334 RMW
Case 5:05-cv-00334-RMW
Document 2313
1
I, Theresa E. Norton, declare as follows:
2
1.
Filed 09/29/2008
Page 2 of 2
I am an attorney with the law firm of Orrick Herrington & Sutcliffe LLP,
3
counsel of record for defendants and counterclaim plaintiffs Nanya Technology Corporation
4
(“Nanya”) and Nanya Technology Corporation USA (“Nanya USA”). Except where it is stated
5
that my knowledge is based on information and belief, I have personal knowledge of the
6
following facts and if called as a witness I could and would testify competently to them.
7
2.
On or about August 22, 2008, I participated in a telephonic meet and confer
8
conference with counsel for Rambus and the other Manufacturers. During that teleconference,
9
the parties discussed possible dates for a deposition of Silicon Graphics, Inc. (“SGI”), a third
10
party subpoenaed for a deposition by Rambus. Rambus did not propose any date on which it
11
might take SGI’s deposition, saying that it was waiting to hear back from SGI as to its
12
availability. The parties discussed that they would expect to schedule this deposition to take
13
place in the first few weeks of September.
14
3.
On September 4, 2008, Rosemarie Ring, counsel for Rambus, circulated to all of
15
the parties a draft stipulation, purportedly representing the parties’ agreement that certain
16
depositions could be taken after the close of discovery. Rambus’ draft stipulation did not
17
include any of the JEDEC witnesses, but it did include SGI. Attached as Exhibit A is a true
18
and correct copy of the draft of the parties’ stipulation that Rambus provided on September 4,
19
2008.
20
4.
On information and belief, Rambus deposed SGI on September 17, 2008.
21 22
I declare under penalty of perjury of the laws of the Unites States of America that the
23
foregoing is true and correct to the best of my knowledge. Executed this 29th day of
24
September, 2008 in Palo Alto, California.
25 /s/ Theresa E. Norton Theresa E. Norton
26 27
OHS West:260523069.1
28 1
NORTON REPLY DECLARATION RE NANYA’S MOTION TO RE-OPEN DISCOVERY CASE NO. C05-00334 RMW
1 2 3 4 5 6 7
Document 2313
Filed 09/29/2008
Page 1 of 2
ROBERT E. FREITAS (STATE BAR NO. 80948) CRAIG R. KAUFMAN (STATE BAR NO. 159458) VICKIE L. FEEMAN (STATE BAR NO. 177487) THERESA E. NORTON (STATE BAR NO. 193530) ORRICK, HERRINGTON & SUTCLIFFE LLP 1000 Marsh Road Menlo Park, CA 94025 Telephone: 650-614-7400 Facsimile: 650-614-7401 Attorneys for Defendants and Counterclaim Plaintiffs NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION U.S.A.
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN JOSE DIVISION
11 RAMBUS INC.,
Case No. CV-05-00334 RMW
12 Plaintiff, 13 v. 14 15 16 17 18 19 20 21 22
HYNIX SEMICONDUCTOR INC., HYNIX SEMICONDUCTOR AMERICA, INC., HYNIX SEMICONDUCTOR MANUFACTURING AMERICA INC., SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, L.P.,
DECLARATION OF THERESA E. NORTON IN SUPPORT OF NANYA TECHNOLOGY CORPORATION AND NANYA TECHNOLOGY CORPORATION USA’S REPLY TO RAMBUS’ OPPOSITION TO THE MOTION RE-OPEN DISCOVERY AS TO CERTAIN DEPOSITIONS Date: Time: Location: Judge:
October 1, 2008 8:30 a.m. Telephonic Hearing Hon. Read A. Ambler (Ret.)
NANYA TECHNOLOGY CORPORATION, NANYA TECHNOLOGY CORPORATION U.S.A., Defendants.
23 24
AND RELATED ACTIONS.
25 26 27 28 NORTON DECLARATION RE NANYA’S MOTION TO RE-OPEN DISCOVERY CASE NO. C05-00334 RMW
Case 5:05-cv-00334-RMW
Document 2313
1
I, Theresa E. Norton, declare as follows:
2
1.
Filed 09/29/2008
Page 2 of 2
I am an attorney with the law firm of Orrick Herrington & Sutcliffe LLP,
3
counsel of record for defendants and counterclaim plaintiffs Nanya Technology Corporation
4
(“Nanya”) and Nanya Technology Corporation USA (“Nanya USA”). Except where it is stated
5
that my knowledge is based on information and belief, I have personal knowledge of the
6
following facts and if called as a witness I could and would testify competently to them.
7
2.
On or about August 22, 2008, I participated in a telephonic meet and confer
8
conference with counsel for Rambus and the other Manufacturers. During that teleconference,
9
the parties discussed possible dates for a deposition of Silicon Graphics, Inc. (“SGI”), a third
10
party subpoenaed for a deposition by Rambus. Rambus did not propose any date on which it
11
might take SGI’s deposition, saying that it was waiting to hear back from SGI as to its
12
availability. The parties discussed that they would expect to schedule this deposition to take
13
place in the first few weeks of September.
14
3.
On September 4, 2008, Rosemarie Ring, counsel for Rambus, circulated to all of
15
the parties a draft stipulation, purportedly representing the parties’ agreement that certain
16
depositions could be taken after the close of discovery. Rambus’ draft stipulation did not
17
include any of the JEDEC witnesses, but it did include SGI. Attached as Exhibit A is a true
18
and correct copy of the draft of the parties’ stipulation that Rambus provided on September 4,
19
2008.
20
4.
On information and belief, Rambus deposed SGI on September 17, 2008.
21 22
I declare under penalty of perjury of the laws of the Unites States of America that the
23
foregoing is true and correct to the best of my knowledge. Executed this 29th day of
24
September, 2008 in Palo Alto, California.
25 /s/ Theresa E. Norton Theresa E. Norton
26 27
OHS West:260523069.1
28 1
NORTON REPLY DECLARATION RE NANYA’S MOTION TO RE-OPEN DISCOVERY CASE NO. C05-00334 RMW
