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Case 5:05-cv-00334-RMW
1
Document 2365
Filed 10/14/2008
Page 1 of 3
[Parties Listed On Signature Page]
2 3 4 5 6 7 8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
10 11
RAMBUS INC.,
12 13 14
CASE NO.: C 05-00334 RMW Plaintiff,
vs. HYNIX SEMICONDUCTOR INC., et al.,
15
Defendant.
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR THE 30(B)(6) DEPOSITION OF NANYA TECHNOLOGY CORPORATION ON DDR3 PRODUCTS Judge:
Hon. Read Ambler (Ret.)
16 17
RAMBUS INC., Plaintiff,
18 19 20
vs. SAMSUNG ELECTRONICS CO., LTD., et al.,
21 22
Defendant. RAMBUS INC.,
23 24 25 26
CASE NO.: C 05-02298 RMW
CASE NO. C-06-00244 RMW Plaintiff,
vs. MICRON TECHNOLOGY INC., et al, Defendants.
27 28 STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
Case 5:05-cv-00334-RMW
1
Document 2365
Filed 10/14/2008
Page 2 of 3
WHEREAS, on October 2, 2008, the Court granted Rambus’ motion to compel a
2
30(b)(6) deposition of Nanya Technology Corporation (“Nanya”) on DDR3 products and ordered
3
that such deposition take place on or before October 17, 2008;
4 5
WHEREAS, the 30(b)(6) witness on DDR3 products that Nanya intends to provide is not available for deposition until October 17, 2008;
6 7
WHEREAS, Nanya requested that the deposition take place during the week of October 20, 2008;
8 9 10
WHEREAS, as the 30(b)(6) witness on DDR3 products that Nanya intends to provide will require a translator (as addressed by the Joint Case Management Order at ¶ 5.c.(6)), Rambus requested that Nanya provide its witness for two days of deposition;
11 12
WHEREAS, the parties have agreed that the deposition of Nanya’s 30(b)(6) witness on DDR3 products may be completed on or before October 24, 2008;
13 14
NOW, THEREFORE, IT IS ORDERED THAT
15
The deadline for the deposition of Nanya’s 30(b)(6) witness on DDR3 products
16
shall be extended to October 24, 2008 accommodate the agreement of counsel as set forth above.
17 18 19 20 SO ORDERED 21 DATED:
_________________
_________________________________
22 The Honorable Read Ambler (Ret.) 23 Special Master 24 25 26 27 28 -1-
STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
Case 5:05-cv-00334-RMW
1
DATED: October 14, 2008
Document 2365
Filed 10/14/2008
Page 3 of 3
MUNGER, TOLLES & OLSON LLP
2
SIDLEY AUSTIN LLP
3
McKOOL SMITH P.C.
4 By: /s/ 5
RAMZI KHAZEN
6 7
Attorneys for RAMBUS INC. DATED: October 14, 2008
8
THERESA E. NORTON ORRICK HERRINGTON & SUTCLIFFE LLP
9 By: /s/
10
THERESA E. NORTON
11
Attorneys for NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION USA
12 13 14 15 16 17 18
Filer’s Attestation: I, Theresa E. Norton, am the ECF user whose identification and password are being used
19
to file this STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE
20
FOR THE 30(b)(6) DEPOSITION OF NANYA TECHNOLOGY CORPORATION ON
21
DDR3 PRODUCTS. In compliance with General Order 45.X.B, I hereby attest that Ramzi
22
Khazen concurs in this filing.
23
By: /s/ Theresa E. Norton Theresa E. Norton
24 25
OHS West:260531152.1
26 27 28 -2-
STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
1
Document 2365
Filed 10/14/2008
Page 1 of 3
[Parties Listed On Signature Page]
2 3 4 5 6 7 8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
10 11
RAMBUS INC.,
12 13 14
CASE NO.: C 05-00334 RMW Plaintiff,
vs. HYNIX SEMICONDUCTOR INC., et al.,
15
Defendant.
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR THE 30(B)(6) DEPOSITION OF NANYA TECHNOLOGY CORPORATION ON DDR3 PRODUCTS Judge:
Hon. Read Ambler (Ret.)
16 17
RAMBUS INC., Plaintiff,
18 19 20
vs. SAMSUNG ELECTRONICS CO., LTD., et al.,
21 22
Defendant. RAMBUS INC.,
23 24 25 26
CASE NO.: C 05-02298 RMW
CASE NO. C-06-00244 RMW Plaintiff,
vs. MICRON TECHNOLOGY INC., et al, Defendants.
27 28 STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
Case 5:05-cv-00334-RMW
1
Document 2365
Filed 10/14/2008
Page 2 of 3
WHEREAS, on October 2, 2008, the Court granted Rambus’ motion to compel a
2
30(b)(6) deposition of Nanya Technology Corporation (“Nanya”) on DDR3 products and ordered
3
that such deposition take place on or before October 17, 2008;
4 5
WHEREAS, the 30(b)(6) witness on DDR3 products that Nanya intends to provide is not available for deposition until October 17, 2008;
6 7
WHEREAS, Nanya requested that the deposition take place during the week of October 20, 2008;
8 9 10
WHEREAS, as the 30(b)(6) witness on DDR3 products that Nanya intends to provide will require a translator (as addressed by the Joint Case Management Order at ¶ 5.c.(6)), Rambus requested that Nanya provide its witness for two days of deposition;
11 12
WHEREAS, the parties have agreed that the deposition of Nanya’s 30(b)(6) witness on DDR3 products may be completed on or before October 24, 2008;
13 14
NOW, THEREFORE, IT IS ORDERED THAT
15
The deadline for the deposition of Nanya’s 30(b)(6) witness on DDR3 products
16
shall be extended to October 24, 2008 accommodate the agreement of counsel as set forth above.
17 18 19 20 SO ORDERED 21 DATED:
_________________
_________________________________
22 The Honorable Read Ambler (Ret.) 23 Special Master 24 25 26 27 28 -1-
STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
Case 5:05-cv-00334-RMW
1
DATED: October 14, 2008
Document 2365
Filed 10/14/2008
Page 3 of 3
MUNGER, TOLLES & OLSON LLP
2
SIDLEY AUSTIN LLP
3
McKOOL SMITH P.C.
4 By: /s/ 5
RAMZI KHAZEN
6 7
Attorneys for RAMBUS INC. DATED: October 14, 2008
8
THERESA E. NORTON ORRICK HERRINGTON & SUTCLIFFE LLP
9 By: /s/
10
THERESA E. NORTON
11
Attorneys for NANYA TECHNOLOGY CORPORATION and NANYA TECHNOLOGY CORPORATION USA
12 13 14 15 16 17 18
Filer’s Attestation: I, Theresa E. Norton, am the ECF user whose identification and password are being used
19
to file this STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE
20
FOR THE 30(b)(6) DEPOSITION OF NANYA TECHNOLOGY CORPORATION ON
21
DDR3 PRODUCTS. In compliance with General Order 45.X.B, I hereby attest that Ramzi
22
Khazen concurs in this filing.
23
By: /s/ Theresa E. Norton Theresa E. Norton
24 25
OHS West:260531152.1
26 27 28 -2-
STIPULATION RE NANYA 30(B)(6) DDR3 DEPOSITION CASE NO. 05-00334 RMW
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