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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`UNIVERSITY OF MASSACHUSETTS and
`CARMEL LABORATORIES, LLC,
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` Plaintiffs,
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`v.
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`L’ORÉAL USA, INC.,
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`Defendant.
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`)
`)
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`) C.A. No. 17-868-CFC-SRF
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`DEFENDANT L’ORÉAL USA, INC.’S NOTICE OF DEPOSITION OF
`KEVIN LEHMAN
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`PLEASE TAKE NOTICE that pursuant to Federal Rule of Civil Procedure 30(b)(1) and
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`the Local Court Rules for the United District Court for the District of Delaware, Defendant
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`L’Oréal USA, Inc. (“Defendant” or “L’Oréal USA”), by its attorneys, will take the deposition
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`upon oral examination either in-person or by remote audio-video conference1 of Kevin Lehman
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`at a date, time and location that is mutually agreeable to the parties. The deposition will continue
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`from day to day, excluding Saturdays, Sundays and legal holidays until complete.
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`The deposition shall be conducted upon oral examination before a court reporter, notary
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`public, or other official authorized to administer oaths under law2, and will be recorded by
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`1
`L’Oréal USA, Inc. reserves the right to take the deposition in-person or by remote audio-
`video conference which will be dependent on the COVID-19 guidelines in place at the time of
`the agreed-upon deposition date. L’Oréal USA will give sufficient notice to plaintiffs regarding
`the format for the deposition.
`2
`Should the deposition proceed by remote audio-video conference, the court reporter may
`administer the oath and take testimony without being in the presence of the deponent, so long as
`the officer or other person before whom the deposition is to be taken can both see and hear the
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`Case 1:17-cv-00868-CFC-SRF Document 143 Filed 05/04/20 Page 2 of 2 PageID #: 4883
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`stenographic, audio, audiovisual, video, and/or real-time computer means. The arrangements for
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`the deposition will be made by counsel for L’Oréal USA and contact information for the
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`reporting service will be provided in advance of the deposition. Counsel for plaintiffs are
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`encouraged to contact the reporting service in advance of an audio-video deposition in order to
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`ensure technology compatability and to complete adequate testing in order to avoid delays.
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`/s/ Katharine L. Mowery
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`Frederick L. Cottrell, III (#2555)
`Jeffrey L. Moyer (#3309)
`Katharine L. Mowery (#5629)
`Richards, Layton & Finger, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, Delaware 19801
`(302) 651-7700
`cottrell@rlf.com
`moyer@rlf.com
`mowery@rlf.com
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`Attorneys for Defendant
`L’Oréal USA, Inc.
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`OF COUNSEL:
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`ERIC W. DITTMANN
`ISAAC S. ASHKENAZI
`NICHOLAS A. TYMOCZKO
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, New York 10166
`(212) 318-6000
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`DENNIS S. ELLIS
`KATHERINE F. MURRAY
`BROWNE GEORGE ROSS LLP
`2121 Avenue of the Stars, Suite 2800
`Los Angeles, California 90067
`(310) 274-7100
`NAVEEN MODI
`JOSEPH E. PALYS
`PAUL HASTINGS LLP
`875 15th Street, N.W.
`Washington, D.C. 20005
`(202) 551-1990
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`Dated: May 4, 2020
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`deponent by audio-video communication equipment or technology for purposes of positively
`identifying the deponent.
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`2
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