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Case 1:23-cv-00758-JLH-SRF Document 211 Filed 12/06/24 Page 1 of 2 PageID #:
`5673
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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) (SRF)
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`ORCA SECURITY LTD.,
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`Plaintiff and
` Counterclaim-Defendant,
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`WIZ, INC.,
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`v.
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`Defendant and
` Counterclaim-Plaintiff.
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`STIPULATION AND [PROPOSED] ORDER TO AMEND DISCOVERY LIMITS
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`IT IS HEREBY STIPULATED AND AGREED by the parties, subject to the approval of
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`the Court, that the discovery limits in D.I. 33 be amended as follows:
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`• ¶ 8(c): “Requests for Admission. A maximum of 60 requests for admission are
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`permitted for each side, excluding document authenticating requests.”
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`• ¶ 8(d): “Interrogatories. (i) A maximum of 35 interrogatories, including contention
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`interrogatories, are permitted for each side.”
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`• ¶ 8(e): “Depositions. (i) Limitation on Hours for Deposition Discovery. Each side is
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`limited to a total of 90 hours of taking testimony of fact witnesses by deposition upon
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`oral examination. If any deposition will require translation, the parties will meet and
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`confer regarding how the translated time should be counted.”
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`Case 1:23-cv-00758-JLH-SRF Document 211 Filed 12/06/24 Page 2 of 2 PageID #:
`5674
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`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
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`/s/ Cameron P. Clark
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`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`Cameron P. Clark (#6647)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`rsmith@morrisnichols.com
`cclark@morrisnichols.com
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`Attorneys for Plaintiff and Counterclaim-
`Defendant Orca Security Ltd.
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`December 6, 2024
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`RICHARDS, LAYTON & FINGER, P.A.
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`/s/ Frederick L. Cottrell, III
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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 and Counterclaim-
`Plaintiff Wiz, Inc.
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`SO ORDERED, this ___ day of December, 2024.
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`UNITED STATES DISTRICT JUDGE
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`2
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`

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