`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Plaintiff,
`
`C.A. No. 1:19-cv-01410-MN
`
`
`
`
`
`VB ASSETS, LLC,
`
`
`
`
`v.
`
`
`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,
`
`
`Defendants.
`
`
`
`NOTICE OF DEPOSITION OF MICHAEL RYE KENNEWICK
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules of Civil Procedure,
`
`defendants Amazon.com, Inc., Amazon.com LLC, Amazon Web Services, Inc., A2Z
`
`Development Center, Inc. d/b/a Lab 126, 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”) will take the deposition by oral testimony of Michael Rye
`
`Kennewick.
`
`The deposition will commence at 9:30 a.m. on April 6, 2022, or a date mutually agreed to
`
`by the parties, and will continue day to day, weekends and holidays excepted, until completed or
`
`adjourned by the attorney(s) taking the deposition. Amazon reserves all rights to reschedule the
`
`deposition until substantial completion of Plaintiff VB Assets’ document production and to reopen
`
`the deposition as necessary if VB Assets produces documents after the deposition takes place. The
`
`{01775632;v1 }
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`1
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`
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`Case 1:19-cv-01410-MN Document 114 Filed 02/25/22 Page 2 of 3 PageID #: 2419
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`
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`deposition will be taken by videoconference in view of the COVID-19 pandemic. The deposition
`
`will be taken before a notary public or other officer authorized by law to administer oaths and will
`
`be recorded by both stenographic and videographic means, as permitted under the current
`
`circumstances. Provisions for real-time monitoring may also be used. Amazon also reserves the
`
`right to utilize Exhibit Capture (picture-in-picture) technology in which any exhibit reviewed by
`
`the deponent during the deposition can be captured visually. Should the deposition be recorded in
`
`either video format, Amazon reserves the right to utilize at trial any portion of the audio or video
`
`recording of the proceeding. In the event Amazon utilizes the stenographic reporting method,
`
`Amazon reserves the right to utilize instant visual display such that the reporter’s record of the
`
`proceeding will be available to all who are a party to this proceeding to request and receive in real-
`
`time.
`
`
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`{01775632;v1 }
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`2
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`
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`Case 1:19-cv-01410-MN Document 114 Filed 02/25/22 Page 3 of 3 PageID #: 2420
`
`
`
`
`
`
`Dated: February 25, 2022
`
`
`Of counsel:
`
`J. David Hadden, CSB No. 176148
`dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`vsalmastlian@fenwick.com
`Johnson Kuncheria, CSB No. 335765
`jkuncheria@fenwick.com
`Min Wu, CSB No. 307512
`min.wu@fenwick.com
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`(650) 988-8500
`
`Jessica Lin, NYB No. 5035860
`jessica.lin@fenwick.com
`FENWICK & WEST LLP
`902 Broadway #14
`New York, NY 10010
`(212) 921-2001
`
`
`
`Respectfully submitted,
`
`
`/s/ Andrew C. Mayo
`Steven J. Balick (#2114)
`sbalick@ashbygeddes.com
`Andrew C. Mayo (#5207)
`amayo@ashbygeddes.com
`ASHBY & GEDDES, P.A.
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`
`Counsel for 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.com
`Services LLC
`
`{01775632;v1 }
`
`3
`
`
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