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`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Kevin P.B. Johnson (Bar No.
`177129)
`kevinjohnson@quinnemanuel.com
`Todd M. Briggs (Bar No. 209282)
`toddbriggs@quinnemanuel.com
`555 Twin Dolphin Drive, 5th Floor
`Redwood Shores, California 94065
`Telephone: (650) 801-5000
`Facsimile: (650) 801-5100
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Eric Huang (pro hac vice)
`erichuang@quinnemanuel.com
`51 Madison Avenue, 22nd Floor
`New York, New York 10010
`Telephone: (212) 849-7000
`Facsimile: (212) 849-7100
`
`Attorneys for Plaintiffs
`NANTWORKS, LLC and NANT
`HOLDINGS IP, LLC
`
`George C. Lombardi (pro hac vice)
`glombardi@winston.com
`WINSTON & STRAWN LLP
`35 West Wacker Drive
`Chicago, IL 60601-9703
`Telephone: (312) 558-5600
`Facsimile: (312) 558-5700
`
`E. Danielle T. Williams (pro hac vice)
`dwilliams@winston.com
`WINSTON & STRAWN LLP
`300 South Tryon Street, 16th Floor
`Charlotte, NC 28202
`Telephone: (704) 350-7700
`Facsimile: (704) 350-7800
`
`Diana Hughes Leiden (SBN: 267606)
`dhleiden@winston.com
`WINSTON & STRAWN LLP
`333 S. Grand Avenue, 38th Floor
`Los Angeles, CA 90071-1543
`Telephone: (213) 615-1700
`Facsimile: (213) 615-1750
`
`Attorneys for Defendants
`BANK OF AMERICA CORPORATION
`and BANK OF AMERICA, N.A.
`
`UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
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`NANTWORKS, LLC, a Delaware
`limited liability company, and NANT
`HOLDINGS IP, LLC, a Delaware
`limited liability company,
`
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`Plaintiffs,
`
`
`BANK OF AMERICA
`CORPORATION, a Delaware
`corporation, and BANK OF
`AMERICA, N.A., a national banking
`association,
`
`
`vs.
`
`Defendants.
`
`
`
` CASE NO. 2:20-cv-7872-GW-PVC
`
`JOINT STATUS REPORT
`Hon. George H. Wu
`
`
`
`
`
`Case No. 2:20-cv-7872-GW-PVC
`JOINT STATUS REPORT
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 283 Filed 11/06/23 Page 2 of 3 Page ID #:4770
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`Pursuant to the Court’s directive (Dkt. 282), Plaintiffs NantWorks LLC and
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`Nant Holdings IP, LLC (“NantWorks”) and Defendants Bank of America Corporation
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`and Bank of America, N.A. (“Bank of America”) jointly submit this status report in
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`advance of the post-mediation status conference on November 9, 2023.
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`The parties participated in in-person mediation with the Honorable Layn R.
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`Phillips (ret.) in Corona Del Mar, California on October 31, 2023. The parties were
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`unable to reach an agreement.
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`Additional Update from Defendants
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`The Parties are continuing to work toward completing all remaining
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`depositions, which due to conflicts are now anticipated to be complete by the end of
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`November, which is after the close of fact discovery.
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`Defendants are also still waiting for additional/supplemental discovery from
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`Plaintiffs relating to Plaintiffs’ alleged trade secrets (and pursuant to this Court’s
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`order), as well as relating to Google Analytics.
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`Additional Update from Plaintiffs
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`In addition to dates for the remaining depositions, Plaintiffs are also waiting for
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`witness designations from Defendants for numerous topics pursuant to Plaintiffs’
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`Rule 30(b)(6) deposition notice. Additionally, Defendants have yet to produce
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`relevant source code that Plaintiffs have requested. Given these outstanding issues,
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`an extension to the current case schedule may be necessary.
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`-2-
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`Case No. 2:20-cv-7872-GW-PVC
`JOINT STATUS REPORT
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`Case 2:20-cv-07872-GW-PVC Document 283 Filed 11/06/23 Page 3 of 3 Page ID #:4771
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`Respectfully submitted,
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`Dated: November 6, 2023
`
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`
`By: /s/ Eric Huang
`Eric Huang
`Attorneys for Plaintiffs
`NANTWORKS, LLC AND NANT
`HOLDINGS IP, LLC
`Dated: November 6, 2023 WINSTON & STRAWN LLP
`
`By: /s/ E. Danielle T. Williams
`E. Danielle T. Williams
`Attorneys for Defendants
`BANK OF AMERICA CORPORATION
`and BANK OF AMERICA, N.A.
`
`FILER’S ATTESTATION
`
`I, Eric Huang, am the ECF user whose ID and password were used to file this
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`JOINT STATUS REPORT. Pursuant to L.R. 5-4.3.4(a)(2), I hereby attest that
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`counsel for Defendants concurred in the content of this document and authorized the
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`filing of this document.
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`By: /s/ Eric Huang
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`-3-
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`Case No. 2:20-cv-7872-GW-PVC
`JOINT STATUS REPORT
`
`
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