Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 1 of 4 PageID #: 27119
`
`JAN 28 2022 “
`
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 1 of4
`
`UNITED STATES DISTRICT COURT
`FOR THE
`DISTRICT OF DELAWARE
`
`US DISTRICT COURT
`DISTRICT OF DELAWARE
`
`
`
`CIVIL ACTION NO.14-cv-1430-LPS-JLH
`
`) )
`
`) )
`
`) )
`
`ELM 3DS INNOVATIONS, LLC.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICSCO., LTD, ET AL.)
`)
`)
`/)
`
`Defendant.
`
`MOTION FOR PROTECTIVE ORDER
`
`RELATIVE TO THE DEPOSITION OF JULIETTE E. LIPPMAN, ES
`SCHEDULED FOR FEBRUARY15, 2022
`
`
`
`COMES NOW,JULIETTEE. LIPPMAN, ESQ., by and through her undersigned counsel and
`
`files the above-referenced Motion for Protective Order Relative to the Deposition of Juliette E.
`
`Lippman, Esq. Scheduled for February 15, 2022 and as groundsthereforestates:
`
`l.
`
`Counsel
`
`for
`
`the Defendant, SAMSUNG ELECTRONICS CO, LTD, ET AL.
`
`(hereinafter
`
`“ Defendant”) has issued a Subpoena to Testify at a Deposition in a Civil Action (hereinafter
`
`Subpoena”) directed to Juliette E. Lippman, Esq. scheduled for February 15, 2022 at 9:00 a.m. A
`
`copyof the referenced Subpoenais attached hereto as Composite Exhibit “A”.
`
`The Subpoena wasserved to Ms. Lippman on January 12, 2022.
`
`2,
`
`The February 15, 2022 Deposition was not coordinated with Ms. Lippman.It was
`
`simply unilaterally scheduled. Ms. Lippmanis not available on February 15,2022. Further, there
`
`is no place for the requested deposition that has been identified.
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 EAST BROWARD BLVD., SUITE 230, FORT LAUDERDALE, FLORIDA 33301-2111 (954) 617-2317
`
`
`
`JAN 28 2022 “
`
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 1 of4
`
`UNITED STATES DISTRICT COURT
`FOR THE
`DISTRICT OF DELAWARE
`
`US DISTRICT COURT
`DISTRICT OF DELAWARE
`
`
`
`CIVIL ACTION NO.14-cv-1430-LPS-JLH
`
`) )
`
`) )
`
`) )
`
`ELM 3DS INNOVATIONS, LLC.,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICSCO., LTD, ET AL.)
`)
`)
`/)
`
`Defendant.
`
`MOTION FOR PROTECTIVE ORDER
`
`RELATIVE TO THE DEPOSITION OF JULIETTE E. LIPPMAN, ES
`SCHEDULED FOR FEBRUARY15, 2022
`
`
`
`COMES NOW,JULIETTEE. LIPPMAN, ESQ., by and through her undersigned counsel and
`
`files the above-referenced Motion for Protective Order Relative to the Deposition of Juliette E.
`
`Lippman, Esq. Scheduled for February 15, 2022 and as groundsthereforestates:
`
`l.
`
`Counsel
`
`for
`
`the Defendant, SAMSUNG ELECTRONICS CO, LTD, ET AL.
`
`(hereinafter
`
`“ Defendant”) has issued a Subpoena to Testify at a Deposition in a Civil Action (hereinafter
`
`Subpoena”) directed to Juliette E. Lippman, Esq. scheduled for February 15, 2022 at 9:00 a.m. A
`
`copyof the referenced Subpoenais attached hereto as Composite Exhibit “A”.
`
`The Subpoena wasserved to Ms. Lippman on January 12, 2022.
`
`2,
`
`The February 15, 2022 Deposition was not coordinated with Ms. Lippman.It was
`
`simply unilaterally scheduled. Ms. Lippmanis not available on February 15,2022. Further, there
`
`is no place for the requested deposition that has been identified.
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 EAST BROWARD BLVD., SUITE 230, FORT LAUDERDALE, FLORIDA 33301-2111 (954) 617-2317
`
`
`
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 2 of 4 PagelD #: 27120
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 2 of 4 PageID #: 27120
`
`Elm 3DS Innovation v Samsung Electronics
`Case No.: 14-cv-1430-LPS-JLH
`Motionfor Protective Order Relative to the
`Deposition ofJuliette E. Lippman, Esq.
`Scheduledfor February 15, 2022.
`Page 2
`
`3,
`
`Ms. Lippmanwasthe attorney for Glenn J. Leedy for a dissolution of marriage matter
`
`which wasfiled in 2011 in the 17" Judicial Circuit of Broward County, Julia A. Leedy v Glenn J.
`
`Leedy, Broward County Case Number FMCE 11-007902. The Final Judgment in this divorce
`
`proceeding was entered on January 7, 2013, approximately 9 years ago. Ms. Lippman is requesting
`
`an Order of Protection as the Subpoena becauseher testimony regarding this matter is protected by
`
`the attorney client privilege. Her former client, Glenn Leedy is deceased and as such, Ms. Lippman
`
`is not aware of his personal representative waiving the attorney-client privilege or the attorney work
`
`product.
`
`4,
`
`Ms. Lippman requests a Court Order regarding the waiver of the attorney-client
`
`privilege should the deposition lawfully proceed.
`
`5.
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`Also, the subpoena does not state a specific location/address for Ms. Lippman’s
`
`deposition. In addition, since the jurisdiction for deposition appears to be Delaware, Ms. Lippman
`
`should not be required to travel for this deposition since she is located in Fort Lauderdale, Florida.
`
`6.
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`Accordingly, for all the reasons stated above, this Honorable Court should enter an
`
`Order
`
`of Protection relative to the taking of the deposition of Juliette E. Lippman, Esq. on February 15,
`
`2022.
`
`7.
`
`That the Defendant has improperly scheduled the deposition of Ms. Lippman, she
`
`requests attorney’s fees and costs relative to the prosecution of this Motion for which the Defendant
`
`should be responsible.
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 EAST BROWARDBLVD., SUITE 230, FORT LAUDERDALE, FLORIDA 33301-2111 (954) 617-2317
`
`
`
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 3 of 4 PagelD #: 27121
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 3 of 4 PageID #: 27121
`
`Elm 3DS Innovation v Samsung Electronics
`Case No.: 14-cv-1430-LPS-JLH
`Motionfor Protective Order Relative to the
`Deposition ofJuliette E. Lippman, Esq.
`Scheduledfor February 15, 2022.
`Page 3
`
`WHEREFORE,JULIETTE E. LIPPMAN, ESQ., respectfully requests this Honorable Court
`
`enter an Order ofProtection relative to the Defendant’s request to take the deposition of Juliette E.
`
`Lippman, Esq. on February 15, 2022, awarding attorney’s fees and costs relative to the prosecution
`
`of this Motion and granting such other and further relief as this Court deems just and proper under
`
`the circumstances.
`
` JULIETTE E. LIPPMAN. ES
`
`STATE OF FLORIDA
`)
`A SS:
`county ox{DUBE5
`The foregoing instrument was acknowledged before me by means of LX,)physical
`presence or (___) online notarization, this ZzZ day
`» 2022, by JULIETTE E.
`
`LIPPMAN, has__producedESQ. who ig-fersonally known “tome or who
`
`
`
`as identification.
`
`
`
`dayscenes2022.
`
`JJDITH E.G, STANLEY
`Pye.
`By
`SES Notary Pudite - State of Forde
`‘ALLE
`Commission # GG 338509
`BS ~ My Comm, Exzires Ju! 30. 2023
`=Boncecthrough hatiora. Notary ASSN.
`
`Notary Public - State of Florida
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 EAST BROWARD BLVD., SUITE 230, FORT LAUDERDALE, FLORIDA 33301-2111 (954) 617-2317
`
`
`
`
`
`
`
`Jieal
`WITNESSmyhandandofficialsealthie |
`
`MyCommission Expires: Ya)2023
`
`
`
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 4 of 4 PagelD #: 27122
`Case 1:14-cv-01430-LPS Document 465 Filed 01/28/22 Page 4 of 4 PageID #: 27122
`
`Elm 3DS Innovation v Samsung Electronics
`Case No.: 14-cv-1430-LPS-JLH
`Motion for Protective Order Relative to the
`Deposition ofJuliette E. Lippman, Esq.
`Scheduledfor February 15, 2022.
`Page 4
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail to
`
`the United States District Court, District of Delaware, Office of the Clerk, 844 North King Street,
`
`Unit 18, Wilmington, DE 19801 and via electronic mail and U.S. Mail to all counsel and parties of
`
`record in this matterlisted in the CM/ECFPortal onthis IPvay ofJanuary, 2022.
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 East Broward Boulevard
`Suite 230
`Fort Lauderdale, FL 33301-2111
`Tel: 954.617.2317
`Fax: 954.617.2313
`E-Service Address: Lippmancourt@kblglaw.com
`
` BY
`
`
`5. LIPPMAN, ESQ.
`4
`Florida Bar No.: 983292
`
`BIRNBAUM, LIPPMAN & GREGOIRE, PLLC
`1301 EAST BROWARD BLVD., SUITE 230, FORT LAUDERDALE, FLORIDA 33301-2111 (954) 617-2317
`
`
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