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Case 5:05-cv-00334-RMW
1
Document 2483
Filed 10/27/2008
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
SECOND STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR ANY MOTION TO COMPEL RESPECTING THE DEPOSITION OF MICRON’S 30(B)(6) WITNESS ON TOPIC 5
Defendant. Judge: Hon. Ronald M. Whyte Courtroom: 6
16 17 18
RAMBUS INC., Plaintiff,
19 20 21
vs. SAMSUNG ELECTRONICS CO., LTD., et al.,
22 23
Defendant. RAMBUS INC.,
24 25 26 27
CASE NO.: C 05-02298 RMW
CASE NO. C-06-00244 RMW Plaintiff,
vs. MICRON TECHNOLOGY INC., et al, Defendants.
28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
05-00334 RMW; 05-02298 RMW; 06-244 RMW
Case 5:05-cv-00334-RMW
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Document 2483
Filed 10/27/2008
Page 2 of 3
WHEREAS, on October 8, 2008, Rambus took the deposition of defendants Micron Technology, Inc. and Micron Semiconductor Products, Inc. (“Micron”) on Topics 4 and 5 of Rambus Inc.’s Amended Notice of Deposition Pursuant to Fed. R. Civ. P. 30(b)(6) Re: Sales of Accused Products (the “Micron 30(b)(6) Deposition”); WHEREAS, pursuant to the parties’ prior agreement and stipulation, Rambus has seven (7) court days from the date on which the Micron 30(b)(6) Deposition was conducted (i.e., until October 20, 2008) to file a motion to compel on testimony objections and documents discovered in such deposition; WHEREAS, pursuant to the parties’ prior stipulation, by order dated October 20, 2008, the Court extended the deadline for Rambus to file a motion to compel respecting Topic 5 in Micron 30(b)(6) Deposition; WHEREAS, the parties have further met and conferred respecting certain issues raised by Rambus regarding the witness’s preparation and testimony as to Topic 5, and intend to continue to meet and confer respecting such issues; WHEREAS, the parties have agreed that Rambus shall have until November 3, 2008, to file a motion to compel respecting Topic 5 in Micron 30(b)(6) Deposition.
17 18 19 20 21 22 23 24 25 26 27 28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
-1-
05-00334 RMW; 05-02298 RMW; 06-244 RMW
Case 5:05-cv-00334-RMW
1 2 3 4 5
Document 2483
Filed 10/27/2008
Page 3 of 3
NOW, THEREFORE, IT IS ORDERED THAT, Rambus shall have until November 3, 2008 to file a motion to compel respecting Topic 5 in the Micron 30(b)(6) Deposition. SO ORDERED DATED:
________________________
____________________________________ The Honorable Read Ambler (ret) Special Master
6 7 8
DATED: October 27, 2008
MUNGER, TOLLES & OLSON LLP
9
SIDLEY AUSTIN LLP
10
McKOOL SMITH P.C.
11 By: /s/ 12
ROLLIN RANSOM
13 14
Attorneys for RAMBUS INC. DATED: October 27, 2008
WEIL, GOTSHAL & MANGES LLP
15 By: /s/
16
ELIZABETH WEISWASSER
17
Attorneys for MICRON TECHNOLOGY INC., et. al.
18 19
Filer's Attestation: 20 I, Rollin Ransom, am the ECF user whose identification and password are being used to 21 file this STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR 22 ANY MOTION TO COMPEL RESPECTING THE DEPOSITION OF MICRON’S 23 30(B)(6) WITNESS ON TOPIC 5. In compliance with General Order 45.X.B, I hereby attest 24 that Elizabeth Weiswasser concurs in this filing. 25 By: _____/s/____________________________ Rollin Ransom
26 27 28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
-2-
05-00334 RMW; 05-02298 RMW; 06-244 RMW
1
Document 2483
Filed 10/27/2008
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
SECOND STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR ANY MOTION TO COMPEL RESPECTING THE DEPOSITION OF MICRON’S 30(B)(6) WITNESS ON TOPIC 5
Defendant. Judge: Hon. Ronald M. Whyte Courtroom: 6
16 17 18
RAMBUS INC., Plaintiff,
19 20 21
vs. SAMSUNG ELECTRONICS CO., LTD., et al.,
22 23
Defendant. RAMBUS INC.,
24 25 26 27
CASE NO.: C 05-02298 RMW
CASE NO. C-06-00244 RMW Plaintiff,
vs. MICRON TECHNOLOGY INC., et al, Defendants.
28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
05-00334 RMW; 05-02298 RMW; 06-244 RMW
Case 5:05-cv-00334-RMW
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Document 2483
Filed 10/27/2008
Page 2 of 3
WHEREAS, on October 8, 2008, Rambus took the deposition of defendants Micron Technology, Inc. and Micron Semiconductor Products, Inc. (“Micron”) on Topics 4 and 5 of Rambus Inc.’s Amended Notice of Deposition Pursuant to Fed. R. Civ. P. 30(b)(6) Re: Sales of Accused Products (the “Micron 30(b)(6) Deposition”); WHEREAS, pursuant to the parties’ prior agreement and stipulation, Rambus has seven (7) court days from the date on which the Micron 30(b)(6) Deposition was conducted (i.e., until October 20, 2008) to file a motion to compel on testimony objections and documents discovered in such deposition; WHEREAS, pursuant to the parties’ prior stipulation, by order dated October 20, 2008, the Court extended the deadline for Rambus to file a motion to compel respecting Topic 5 in Micron 30(b)(6) Deposition; WHEREAS, the parties have further met and conferred respecting certain issues raised by Rambus regarding the witness’s preparation and testimony as to Topic 5, and intend to continue to meet and confer respecting such issues; WHEREAS, the parties have agreed that Rambus shall have until November 3, 2008, to file a motion to compel respecting Topic 5 in Micron 30(b)(6) Deposition.
17 18 19 20 21 22 23 24 25 26 27 28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
-1-
05-00334 RMW; 05-02298 RMW; 06-244 RMW
Case 5:05-cv-00334-RMW
1 2 3 4 5
Document 2483
Filed 10/27/2008
Page 3 of 3
NOW, THEREFORE, IT IS ORDERED THAT, Rambus shall have until November 3, 2008 to file a motion to compel respecting Topic 5 in the Micron 30(b)(6) Deposition. SO ORDERED DATED:
________________________
____________________________________ The Honorable Read Ambler (ret) Special Master
6 7 8
DATED: October 27, 2008
MUNGER, TOLLES & OLSON LLP
9
SIDLEY AUSTIN LLP
10
McKOOL SMITH P.C.
11 By: /s/ 12
ROLLIN RANSOM
13 14
Attorneys for RAMBUS INC. DATED: October 27, 2008
WEIL, GOTSHAL & MANGES LLP
15 By: /s/
16
ELIZABETH WEISWASSER
17
Attorneys for MICRON TECHNOLOGY INC., et. al.
18 19
Filer's Attestation: 20 I, Rollin Ransom, am the ECF user whose identification and password are being used to 21 file this STIPULATION AND [PROPOSED] ORDER TO EXTEND THE DEADLINE FOR 22 ANY MOTION TO COMPEL RESPECTING THE DEPOSITION OF MICRON’S 23 30(B)(6) WITNESS ON TOPIC 5. In compliance with General Order 45.X.B, I hereby attest 24 that Elizabeth Weiswasser concurs in this filing. 25 By: _____/s/____________________________ Rollin Ransom
26 27 28 SECOND STIP. AND [PROP’D] ORDER EXTENDING TIME FOR ANY MOTION TO COMPEL MICRON’S 30(B)(6) DEPOSITION ON TOPIC 5
-2-
05-00334 RMW; 05-02298 RMW; 06-244 RMW
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