`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
` C.A. No. 20-00925-JFB- SRF
`
`JURY TRIAL DEMANDED
`
`))))))))))))
`
`HOLOGIC, INC. and CYTYC SURGICAL
`PRODUCTS, LLC,
`
`Plaintiffs,
`
`v.
`
`MINERVA SURGICAL, INC.,
`
`Defendant.
`
`DEFENDANT MINERVA SURGICAL, INC.’S NOTICE OF
`RULE 30(B)(6) DEPOSITION OF PLAINTIFFS
`
`PLEASE TAKE NOTICE, that pursuant to Rule 30(b)(6) of the Federal Rules of Civil
`
`Procedure, Defendant Minerva Surgical, Inc. (“Minerva”), by and through its counsel of record,
`
`will take the oral deposition of Plaintiffs Hologic, Inc. and Cytyc Surgical Products, LLC
`
`(collectively, “Hologic” or “Plaintiffs”), through one or more of its officers, directors, or
`
`managing agents, or other persons who consent to testify on their behalf, with regard to the
`
`matters set forth in the attached Schedule A. Minerva requests that Hologic identify in writing at
`
`least seven (7) days in advance of the deposition the person(s) designated by Hologic 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 depositions will take place at mutually agreeable dates and locations as may be
`
`agreed upon by the parties. The deposition will be taken before a qualified notary public or other
`
`officer authorized by law to administer oaths, and will continue from day-to-day, excluding
`
`weekends and holidays, until completed. The testimony will be recorded stenographically and
`
`videotaped. You are invited to attend.
`
`
`
`Case 1:20-cv-00925-JFB-SRF Document 40 Filed 12/07/20 Page 2 of 2 PageID #: 812
`
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`/s/ Ian R. Liston
`Ian R. Liston (#5507)
`222 Delaware Avenue, Suite 800
`Wilmington, DE 19801
`(302) 304-7600
`iliston@wsgr.com
`
`Counsel for Defendant
`Minerva Surgical, Inc.
`
`DATED: December 7, 2020
`
`Of Counsel:
`
`Vera M. Elson
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`(650) 493-9300
`velson@wsgr.com
`
`Olivia M. Kim
`Erik J. Carlson
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`633 West Fifth Street, 15th Floor
`Los Angeles, CA 90071
`(323) 210-2900
`okim@wsgr.com
`ecarlson@wsgr.com
`
`-2-
`
`
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