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Case 1:22-cv-00311-WCB Document 220 Filed 09/28/23 Page 1 of 3 PageID #: 16081
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`IMPOSSIBLE FOODS INC.,
`)
`)
`Plaintiff,
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`v.
`MOTIF FOODWORKS, INC. and
`GINKGO BIOWORKS, INC.,
`Defendants.
`
`C.A. No. 22-311 (WCB)
`
`DEFENDANT’S NOTICE OF DEPOSITION PURSUANT TO FED. R. CIV. P. 30(b)(1)
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`PLEASE TAKE NOTICE that Defendant Motif FoodWorks, Inc. (“Motif”), by its
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`undersigned attorneys, hereby gives notice of its intention to take the deposition upon oral
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`examination of Nate Gorence pursuant to Rule 30(b)(1) of the Federal Rules of Civil Procedure.
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`The deposition will commence at a date and time to be mutually agreed upon by counsel, and will
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`continue until completion with such adjournments as may be necessary. The deposition will
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`take place at the law offices of Quinn Emanuel Urquhart & Sullivan, LLP, 555 Twin Dolphin
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`Dr., 5th Floor, Redwood Shores, CA 94065, or at a location to be mutually agreed upon in writing
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`by counsel for the parties, including by remote means, if necessary. You are invited to attend
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`and cross-examine. The deposition will be conducted before an officer authorized to
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`administer oaths and will continue from day-to-day until completed. The testimony will be
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`recorded by stenographic, audio, video, and/or real-time transcription means.
`
`1
`
`

`

`Case 1:22-cv-00311-WCB Document 220 Filed 09/28/23 Page 2 of 3 PageID #: 16082
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`
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`OF COUNSEL:
`
`Joseph M. Paunovich
`Ryan Landes
`Sandra L. Haberny
`Sarah Cork
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`865 South Figueroa Street
`10th Floor
`Los Angeles, CA 90017
`(213) 443-3000
`
`Stephen Q. Wood
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`2755 E. Cottonwood Parkway
`Suite 430
`Salt Lake City, UT 84121
`(801) 515-7300
`
`September 28, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Jeremy A. Tigan
`
`
`
`
`Jeremy A. Tigan (#5239)
`Lucinda C. Cucuzzella (#3491)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jtigan@morrisnichols.com
`ccucuzzella@morrisnichols.com
`
`Attorneys for Defendant Motif FoodWorks,
`Inc.
`
`
`2
`
`

`

`Case 1:22-cv-00311-WCB Document 220 Filed 09/28/23 Page 3 of 3 PageID #: 16083
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on September 28, 2023, a copy of the foregoing document was
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`served via electronic mail upon the following counsel of record.
`
`
`VIA ELECTRONIC MAIL
`Matthew R. Reed, Esquire
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road Palo Alto,
`CA 94304
`Attorneys for Plaintiff Impossible Foods Inc.
`
`VIA ELECTRONIC MAIL
`Wendy L. Devine, Esquire
`Susannah M. L. Gagnon, Esquire
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza Spear Tower, Suite 3300
`San Francisco, CA 94105
`Attorneys for Plaintiff Impossible Foods Inc.
`
`VIA ELECTRONIC MAIL
`Lorelei P. Westin, Esquire
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`12235 El Camino Real San Diego, CA 92130
`Attorneys for Plaintiff Impossible Foods Inc.
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`
`
`Dated: September 28, 2023
`
`
`
`
`
`
`
`
`/s/ Jeremy A. Tigan
`Jeremy A. Tigan (#5239)
`
`3
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`

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