`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`
`C.A. No. 19-1410-MN
`
`
` VB ASSETS, LLC
`
` Plaintiff,
`
` v.
`
` AMAZON.COM SERVICES LLC,
`
` Defendants.
`
`
`
`
`
`
`
`
`JOINT MOTION FOR EXEMPTION OF PERSONS FROM THE DISTRICT OF
`DELAWARE’S MAY 15, 2023 STANDING ORDER ON PERSONAL DEVICES
`
`Plaintiff VB Assets, LLC and Defendant Amazon.com Services LLC jointly move (the
`
`“Motion”) for an Order to exempt certain persons from the District of Delaware’s May 15, 2023
`
`Standing Order on Procedures Regarding the Possession and Use of Cameras and Personal
`
`Electronic Devices by Visitors to the J. Caleb Boggs Federal Building and United States
`
`Courthouse (the “May 15, 2023 Standing Order”). In support of this Motion, the parties state as
`
`follows:
`
`1.
`
`The District of Delaware’s May 15, 2023 Standing Order provides procedures to
`
`regulate the possession and use of personal electronic devices by visitors to the J. Caleb Boggs
`
`Federal Building and United States Courthouse, which require inter alia, for visitors to place
`
`personal electronic devices in a locked pouch provided by U.S. Marshals. Paragraph 4 of the May
`
`15, 2023 Standing Order provides for certain exemptions to the Standing Order.
`
`2.
`
`A trial is scheduled in this case for November 2 through November 8, 2023. A pre-
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`trial conference is scheduled for October 30, 2023 at 3:30pm. At the pre-trial conference, the
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`parties anticipate scheduling a time to conduct their courtroom setup for the trial.
`
`
`
`Case 1:19-cv-01410-MN Document 252 Filed 10/27/23 Page 2 of 3 PageID #: 10654
`
`3.
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`The following persons will attend the pre-trial conference and/or trial and need
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`access to their electronic devices, but do not have a state issued bar card or meet the exemptions
`
`listed in Paragraph 4 of the May 15, 2023 Standing Order:
`
`Paralegals
`
`Apriljoy Sanchez
`Jeremy Ra
`Chris Howland
`Bruce Chiang
`Robyn Finnimore-Pierce
`Arlene Apodaca
`Albert Garcia
`Kathie Ramos
`
`Clients and Consultants
`
`Scott Sanford (Amazon)
`Jason Bloom (Bloom Strategic Consulting)
`Brian Patterson (IMS Consulting)
`Bill Smith (Advanced Courtroom Technologies)
`Matthew Hegerle (Advanced Courtroom Technologies)
`Tara Trask (Trask Consulting)
`
`Witnesses
`
`Nikko Ström
`Keith Ugone (Defendant’s expert)
`Michael T. Johnson (Defendant’s expert)
`Brett Reed (Plaintiff’s expert)
`Nathaniel Polish (Plaintiff’s expert)
`John Peck (Plaintiff’s expert)
`Michael Kennewick
`Richard Kennewick
`Thomas Freeman
`
`
`WHEREFORE, the parties respectfully request that the Court exempt the listed individuals
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`from the May 15, 2023 Standing Order.
`
`
`
`
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 252 Filed 10/27/23 Page 3 of 3 PageID #: 10655
`
`Dated: October 27, 2023
`
`SMITH, KATZENSTEIN & JENKINS, LLP
`
`ASHBY & GEDDES
`
`/s/ Jason Z. Miller
`Neal C. Belgam (No. 2721)
`Jason Z. Miller (No. 6310)
`1000 West Street, Suite 1501
`Wilmington, DE 19801
`(302) 652-8400
`nbelgam@skjlaw.com
`jzm@skjlaw.com
`
`Of counsel:
`
`Ryan R. Smith
`James C. Yoon
`Wilson Sonsini Goodrich & Rosati
`650 Page Mill Road
`Palo Alto, CA 94304
`rsmith@wsgr.com
`jyoon@wsgr.com
`
`Ryan S. Benyamin
`Jamie Y. Otto
`Wilson Sonsini Goodrich & Rosati
`633 West Fifth Street; Suite 1550
`Los Angeles, CA 90071
`rbenyamin@wsgr.com
`jotto@wsgr.com
`
`Counsel for Plaintiff VB Assets, LLC
`
`/s/ Steven J. Balick
`Steven J. Balick (No. 2114)
`Andrew C. Mayo (No. 5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`
`Of counsel:
`
`J. David Hadden, CSB No. 176148
`Saina S. Shamilov, CSB No. 215636
`Ravi R. Ranganath, CSB No. 272981
`Vigen Salmastlian, CSB No. 276846
`Allen Wang, CBS No. 278953
`Johnson Kuncheria, CSB No. 335765
`Min Wu, CSB No. 307512
`Jeffrey A. Ware, CSB No. 271603
`Rebecca A.E. Fewkes, CSB No. 209168
`FENWICK & WEST LLP
`801 California Street
`Mountain View, CA 94041
`(650) 988-8500
`dhadden@fenwick.com
`sshamilov@fenwick.com
`rranganath@fenwick.com
`vsalmastlian@fenwick.com
`awang@fenwick.com
`min.wu@fenwick.com
`jkuncheria@fenwick.com
`jware@fenwick.com
`rfewkes@fenwick.com
`
`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
`
`3
`
`
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