`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB Assets, LLC,
`Plaintiff,
`
`v.
`Amazon.com, Inc.et al.,
`Defendants.
`
`C.A. No. 19-1410 (MN)
`JURY TRIAL DEMANDED
`
`PLAINTIFF VB ASSETS, LLC’S NOTICE OF DEPOSITION OF DEFENDANTS
`PURSUANT TO FED. R. CIV. P. 30(B)(6): TECHNICAL TOPICS
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil
`
`Procedure, Plaintiff VB Assets, LLC (“VoiceBox” or “Plaintiff”) will take the deposition of
`
`Defendants Amazon.com, Inc.; Amazon.com LLC; Amazon Web Services, Inc.; A2Z
`
`Development Center, Inc. d/b/a Lab126; Rawles LLC; AMZN Mobile LLC; AMZN Mobile 2
`
`LLC; Amazon.com Services, Inc. f/k/a Amazon Fulfillment Services, Inc.; and Amazon Digital
`
`Services LLC (collectively, “Amazon” or “Defendants”), through one or more of its officers,
`
`directors, or managing agents, or other persons who consent to testify on Amazon’s behalf, with
`
`regard to the matters set forth in the attached Schedule A. VoiceBox requests that Amazon
`
`identify in writing at least seven (7) days in advance of the deposition, or such other time frame
`
`as agreed by the parties, the person(s) designated by Amazon to testify on its behalf, the job title
`
`of each such person(s), and the topic(s) on which each such person(s) will testify.
`
`The deposition will commence on February 4, 2022, or a date to be mutually agreed by
`
`the parties by remote deposition means if mutually agreed by the parties, or at such other
`
`location mutually agreed upon by the parties. The deposition will take place pursuant to the
`
`Federal Rules of Civil Procedure and applicable Local Rules of the United States District Court
`
`for the District of Delaware before a qualified Notary Public or other officer duly authorized by
`
`
`
`Case 1:19-cv-01410-MN Document 109 Filed 01/14/22 Page 2 of 3 PageID #: 2395
`
`law to administer oaths, and will continue day to day, excluding weekends and holidays, until
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`completed with such adjournments as time and place that may be necessary. The deposition will
`
`be recorded by stenographic means and will be audiotaped and/or videotaped.
`
`VoiceBox reserves its rights to serve additional deposition topics on different subject
`
`matter or based on its receipt of additional discovery and/or further investigation.
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 109 Filed 01/14/22 Page 3 of 3 PageID #: 2396
`
`Dated: January 14, 2022
`
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`
`By: /s/ Ian R. Liston
`Ian R. Liston (Delaware Bar I.D. # 5507)
`Jennifer A. Ward (Delaware Bar I.D. # 6476)
`222 Delaware Avenue
`Suite 800
`Wilmington, DE 19801
`iliston@wsgr.com
`jward@wsgr.com
`Telephone: (302) 304-7600
`Facsimile: (866) 974-7329
`
`Edward G. Poplawski, admitted pro hac vice
`Erik J. Carlson, admitted pro hac vice
`Ryan S. Benyamin, admitted pro hac vice
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071-2027
`epoplawski@wsgr.com
`ecarlson@wsgr.com
`rbenyamin@wsgr.com
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`James C. Yoon, admitted pro hac vice
`Ryan Smith, admitted pro hac vice
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`jyoon@wsgr.com
`rsmith@wsgr.com
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`Attorneys for VB Assets, LLC
`
`3
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`
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