`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 22-904 (RGA) (SRF)
`
`REDACTED – PULIC VERSION
`Original Filing Date: June 20, 2023
`Redacted Filing Date: June 20, 2023
`
`)))))))))
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`
`
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON WEB SERVICES, INC.,
`
`Defendant.
`
`DEFENDANT AMAZON WEB SERVICES, INC.’S NOTICE OF SUBPOENAS
`TO VIRGIL BOURASSA
`
`PLEASE TAKE NOTICE that the subpoenas attached hereto as Exhibits A and B will be
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`served upon Virgil Bourassa. Pursuant to Fed R. Civ. P. 34 and 45, Defendant Amazon Web
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`Services (“Amazon”) provides notice that it, through undersigned counsel, requests the
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`production of documents by third party Virgil Bourassa, on July 21, 2023 at 9:00 am, at the
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`office of Fisch Sigler LLP, 400 Concar Drive, San Mateo, CA 94402, or at another mutually
`
`agreeable time and place.
`
`Please take further notice that Amazon will take the oral deposition of Virgil Bourassa on
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`August 4, 2023 at 9:00 am at the office of Fisch Sigler LLP, 400 Concar Drive, San Mateo, CA
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`94402, or at another mutually agreeable time and place. The deposition may also proceed
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`remotely. The deposition will be taken before a notary public or other officer authorized to
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`administer an oath and will continue day-to-day until concluded or may be continued until
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`completed at a future date(s). Pursuant to Fed R. Civ. P. 30(b)(3), the deposition will be
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`videotaped and/or recorded stenographically.
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`
`
`Case 1:22-cv-00904-RGA-SRF Document 55 Filed 06/20/23 Page 2 of 3 PageID #: 13040
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Jennifer Ying
`
`Jack B. Blumenfeld (#1014)
`Jennifer Ying (#5550)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`jying@morrisnichols.com
`
`Attorneys for Defendant Amazon Web Services,
`Inc.
`
`OF COUNSEL:
`
`Alan M. Fisch
`R. Williams Sigler
`Jeffrey M. Saltman
`Lisa N. Phillips
`FISCH SIGLER LLP
`5301 Wisconsin Avenue NW, Suite 400
`Washington, DC 20015
`(202) 362-3500
`
`June 20, 2023
`
`2
`
`
`
`Case 1:22-cv-00904-RGA-SRF Document 55 Filed 06/20/23 Page 3 of 3 PageID #: 13041
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on June 20, 2023, I caused the foregoing to be electronically filed
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`with the Clerk of the Court using CM/ECF, which will send notification of such filing to all
`
`registered participants.
`
`I further certify that I caused copies of the foregoing document to be served on
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`June 20, 2023, upon the following in the manner indicated:
`
`Philip A. Rovner, Esquire
`Jonathan A. Choa, Esquire
`POTTER ANDERSON & CORROON LLP
`1313 North Market Street, 6th Floor
`Wilmington, DE 19801
`Attorneys for Plaintiff
`
`Paul J. Andre, Esquire
`Lisa Kobialka, Esquire
`James R. Hannah, Esquire
`Michael H. Lee, Esquire
`Christina Finn, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`333 Twin Dolphin Drive, Suite 700
`Redwood Shores, CA 94065
`Attorneys for Plaintiff
`
`Aaron M. Frankel, Esquire
`Marcus A. Colucci, Esquire
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`1177 Avenue of the Americas
`New York, NY 10036
`Attorneys for Plaintiff
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`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`VIA ELECTRONIC MAIL
`
`/s/ Jennifer Ying
`
`Jennifer Ying (#5550)
`
`3
`
`
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