`
`
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`James R. Asperger (Bar No. 83188)
`jimasperger@quinnemanuel.com
`Rachael McCracken
`rachaelmccracken@quinnemanuel.com
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017-2543
`Telephone: (213) 443-3000
`Facsimile: (213) 443-3100
`
` QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Kevin P.B. Johnson (Bar No. 177129)
`kevinjohnson@quinnemanuel.com
`Todd M. Briggs (Bar No. 209282)
`toddbriggs@quinnemanuel.com
`Brice C. Lynch (Bar No. 288567)
`bricelynch@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
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
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`Case No. 2:20-cv-7872-GW-PVC
`NANTWORKS’ NOTICE OF UPDATED MEMORANDUM IN SUPPORT OF MOTION TO EXCLUDE CERTAIN
`EXPERT OPINIONS AND TESTIMONY OF DAWN HALL AND DR. JAMES STORER
`
`NANTWORKS, LLC, a Delaware
`limited liability company, and NANT
`HOLDINGS IP, LLC, a Delaware
`limited liability company,
`
`
`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
`
`NANTWORKS’ NOTICE OF
`UPDATED MEMORANDUM IN
`SUPPORT OF MOTION TO
`EXCLUDE CERTAIN EXPERT
`OPINIONS AND TESTIMONY OF
`DAWN HALL AND DR. JAMES
`STORER
`
`
`
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 483 Filed 05/30/24 Page 2 of 3 Page ID #:59688
`
`
`PLEASE TAKE NOTICE that Plaintiffs NantWorks LLC and Nant Holding
`
`IP, LLC (“NantWorks”) submitted an updated memorandum in support of its Motion
`
`to Exclude Certain Expert Opinions and Testimony of Dawn Hall and Dr. James
`
`Storer (“Motion to Exclude”) (Dkt. 334).
`
`NantWorks filed its original Motion to Exclude on May 3, 2024 pursuant to the
`
`case schedule. However, as noted in NantWorks’ original motion, Bank of America
`
`contended that Ms. Hall was not available to be deposed prior to the May 3, 2024
`
`deadline for filing Daubert motions, such that NantWorks was unable to include her
`testimony in its May 3, 2024 filing. See Dkt. 337-1 at 1, n.1.1 The original supporting
`
`memorandum (Dkt. 337-1) is now replaced with the version filed today (Dkt. 482-1).
`
`NantWorks received the final transcript for Ms. Hall’s May 17, 2024 deposition
`
`on May 24, 2024 and promptly supplemented and amended its original memorandum
`
`of law to incorporate Ms. Hall’s testimony and include additional authority based
`
`thereon. If it would be helpful to the Court, NantWorks can provide a redline showing
`
`the changes that have been made to its original memorandum.
`
`
`
`
`
`
`1 Bank of America also served an “errata” making substantive changes to Ms.
`Hall’s report on April 30, 2024, just prior to the deadline for filing Daubert motions.
`Ex. 8 (April 30, 2024 Errata to Hall Reb. Rpt.).
`
`1
`Case No. 2:20-cv-7872-GW-PVC
`NANTWORKS’ NOTICE OF UPDATED MEMORANDUM IN SUPPORT OF MOTION TO EXCLUDE CERTAIN
`EXPERT OPINIONS AND TESTIMONY OF DAWN HALL AND DR. JAMES STORER
`
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`Case 2:20-cv-07872-GW-PVC Document 483 Filed 05/30/24 Page 3 of 3 Page ID #:59689
`
`
`
`
`2
`Case No. 2:20-cv-7872-GW-PVC
`NANTWORKS’ NOTICE OF UPDATED MEMORANDUM IN SUPPORT OF MOTION TO EXCLUDE CERTAIN
`EXPERT OPINIONS AND TESTIMONY OF DAWN HALL AND DR. JAMES STORER
`
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`DATED: May 30, 2024
`
`Respectfully submitted,
`
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`
`By
`/s/ Rachael McCracken
`James R. Asperger
`Kevin P.B. Johnson
`Todd M. Briggs
`Eric Huang
`Rachael McCracken
`Brice C. Lynch
`
`Attorneys for Plaintiff, NANTWORKS,
`LLC and NANT HOLDINGS IP, LLC
`
`
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