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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 23-758 (JLH)
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`ORCA SECURITY LTD.,
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`v.
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`WIZ, INC.,
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`Plaintiff,
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`Defendant.
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`STIPULATION AND PROPOSED ORDER
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`WHEREAS, Plaintiff Orca Security Ltd. (“Orca”) and Defendant Wiz, Inc. (“Wiz;”
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`collectively, the “Parties”) have served Priority Electronic Correspondence production requests
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`(“Priority Requests”) on each other as well as corresponding objections and hit counts pursuant to
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`the Stipulation and Order Regarding Discovery of Electronically Stored Information (D.I. 71; the
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`“ESI Order”);
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`WHEREAS, the Parties have continued meeting and conferring regarding the Priority
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`Requests;
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`WHEREAS, the current deadline to submit disputes regarding the Priority Requests is
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`Tuesday, July 16;
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`WHEREAS, the Parties believe continuing their meet and confer efforts is likely to result
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`in narrowing of their disputes;
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`WHEREAS, extending deadlines relating to Electronic Correspondence production
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`requests will not affect the time for any Court hearing, conference, or trial;
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`IT IS HEREBY STIPULATED by the Parties, subject to the approval of the Court, that the
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`following dates in the ESI Order (D.I. 71), shall be amended as follows:
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`Case 1:23-cv-00758-JLH Document 105 Filed 07/16/24 Page 2 of 2 PageID #: 2178
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`Event
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`Current Date
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`Amended Date
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`Deadline to submit Priority Request
`disputes
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`Deadline to substantially complete
`production in response to Priority
`Requests
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`Deadline for objections to remaining
`Electronic Correspondence requests
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`July 16, 2024
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`July 19, 2024
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`August 27, 2024
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`August 30, 2024
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`The later of September
`10, 2024 or within 21
`days of receipt
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`The later of September
`13, 2024 or within 21
`days of receipt
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`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
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`/s/ Rodger D. Smith II
`___________________________________
`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`rsmith@morrisnichols.com
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`Attorneys for Plaintiff
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`July 9, 2024
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`RICHARD, LAYTON & FINGER, P.A.
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`/s/ Christine D. Haynes
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`Frederick L. Cottrell, III (#2555)
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`farnan@rlf.com
`haynes@rlf.com
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`Attorneys for Defendant
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`SO ORDERED, this _____ day of July 2024.
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`_______________________________
`The Honorable Jennifer L. Hall
`United States District Court Judge
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`2
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