`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`IMPOSSIBLE FOODS INC.,
`
`Plaintiff,
`
`v.
`
`MOTIF FOODWORKS, INC., and
`GINKGO BIOWORKS, INC.,
`
`Defendants.
`
`Case No. 1:22-cv-00311-WCB
`
`JURY TRIAL DEMANDED
`
`DEFENDANT’S NOTICE OF DEPOSITION OF ELAINE PAIK
`PURSUANT TO FED. R. CIV. P. 30(B)(1)
`
`PLEASE TAKE NOTICE that Defendant Ginkgo Bioworks, Inc. (“Ginkgo”), by its
`
`undersigned attorneys, hereby gives notice of its intention to take the deposition upon oral
`
`examination of Elaine Paik pursuant to Rule 30(b)(1) of the Federal Rules of Civil Procedure. The
`
`deposition will commence at 9:00 a.m. PT on April 19, 2024 and will continue until completion
`
`with such adjournments as may be necessary. The deposition will take place at the law offices of
`
`Morrison & Foerster LLP, 425 Market Street, San Francisco, CA 94105-2482 or at a location to
`
`be mutually agreed upon in writing by counsel for the parties, including by remote means, if
`
`necessary. You are invited to attend and cross-examine. The deposition will be conducted before
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`an officer authorized to administer oaths and will continue from day-to-day until completed. The
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`testimony will be recorded by stenographic, audio, video, and/or real-time transcription means.
`
`ME1 47817636v.1
`
`1
`
`
`
`Case 1:22-cv-00311-WCB Document 385 Filed 03/06/24 Page 2 of 2 PageID #: 23751
`
`MCCARTER & ENGLISH, LLP
`
`/s/ Alexandra M. Joyce
`Daniel M. Silver (#4758)
`Alexandra M. Joyce (#6423)
`Renaissance Centre
`405 N. King Street, 8th Floor
`Wilmington, Delaware 19801
`(302) 984-6300
`dsilver@mccarter.com
`ajoyce@mccarter.com
`
`Attorneys for Defendant Ginkgo Bioworks,
`Inc.
`
`Dated: March 6, 2024
`
`OF COUNSEL:
`
`Daralyn J. Durie
`Adam R. Brausa
`Vera Ranieri
`Morrison & Foerster LLP
`425 Market Street
`San Francisco, CA 94105-2482
`415.268.7000
`ddurie@mofo.com
`abrausa@mofo.com
`vranieri@mofo.com
`
`Aaron D. Bray
`Morrison & Foerster LLP
`755 Page Mill Road
`Palo Alto, CA, 94304-1018
`650-813-5600
`abray@mofo.com
`
`Caleb D. Woods
`Morrison & Foerster LLP
`2100 L Street, NW Suite 900
`Washington DC
`202-887-1500
`cwoods@mofo.com
`
`ME1 47817636v.1
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`2
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