`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 1:19-cv-01410-MN
`
`VB ASSETS, LLC,
`
`
`
`
`v.
`
`Plaintiff,
`
`
`
`
`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.
`
`
`
`JOINT STIPULATION AND [PROPOSED] ORDER
`
`WHEREAS, on May 20, 2022, this Court entered an Order amending the Scheduling Order
`
`in this action, including setting a fact discovery deadline of June 24, 2022; and
`
`WHEREAS, multiple depositions have been postponed and have been rescheduled due to
`
`health issues, including COVID-19 infection, of both witnesses and counsel;
`
`IT IS HEREBY STIPULATED AND AGREED, subject to the approval and Order of the
`
`Court, that notwithstanding the June 24, 2022 close of fact discovery (see May 20, 2022 Order),
`
`the parties agree to complete the depositions of David Thomas on June 29, 2022, Rino Caruccio
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`on June 29, 2022, Kuansan Wang on June 30, 2022, and Kelly Vanee on July 1, 2022.1 The parties
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`agree that the depositions shall be treated for all purposes as if they were conducted within the fact
`
`discovery period.
`
`
`1 The parties also plan to schedule the continuation of the deposition of third-party Marco Petroni
`of Nuance Communications Inc. after the close of fact discovery, but will file any such
`stipulation separately, as the date is not yet confirmed.
`
`
`
`1
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`
`
`Case 1:19-cv-01410-MN Document 169 Filed 06/27/22 Page 2 of 3 PageID #: 2616
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`
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`No other dates are to be changed at this stage absent the Court’s instruction or Order to the
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`contrary.
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`The undersigned counsel hereby certify that they provided a copy of this stipulation to their
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`clients in compliance with District of Delaware Local Rule 16.4(b).
`
`
`
`
`
`
`
`
`
`2
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`
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`Case 1:19-cv-01410-MN Document 169 Filed 06/27/22 Page 3 of 3 PageID #: 2617
`
`WILSON SONSINI GOODRICH & ROSATI
`
`ASHBY & GEDDES
`
`/s/ Ian R. Liston
`
`/s/ Steven J. Balick
`
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`Telephone: (302) 654-1888
`
`Of Counsel:
`
`J. David Hadden, CSB No. 176148
`Email: dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`Email: sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Johnson Kuncheria, CSB No. 335765
`jkuncheria@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`Email: vsalmastlian@fenwick.com
`Sapna Mehta, CSB No. 288238
`Email: smehta@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.520
`
`Attorneys 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 Digital Services LLC
`
`Ian R. Liston (#5507)
`Jennifer A. Ward (#6476)
`222 Delaware Avenue, Suite 800
`Wilmington, DE 19801
`iliston@wsgr.com
`jward@wsgr.com
`Telephone: (302) 304-7600
`
`Of Counsel:
`
`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
`Jamie Y. Otto, 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
`
`SO ORDERED this 27th day of June 2022.
`
`____________________________________
`The Honorable Maryellen Noreika
`United States District Judge
`
`3
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`
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