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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ORCA SECURITY LTD.,
`
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`Plaintiff,
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`
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`v.
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`WIZ, INC.,
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`
`
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`Defendant.
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`
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`
`
`C.A. No. 23-758 (JLH)
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`)
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`)
`)
`)
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`JOINT MOTION FOR TELECONFERENCE TO RESOLVE DISCOVERY DISPUTES
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`Plaintiff Orca Security Ltd. and Defendant Wiz, Inc. respectfully move this Court
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`to schedule a teleconference to address outstanding disputes regarding the following discovery
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`matters.
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`Plaintiff Orca Security Ltd.’s Issues For Teleconference:
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`1.
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`Defendants’ responses to Plaintiff’s Interrogatory Nos. 1, 2, 6, 7, and 12,
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`including Defendants’ withholding of relevant source code and git history.
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`2.
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`Defendants’ responses to Plaintiffs’ Second Set of Requests for Production
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`(Nos. 84-90).
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`3.
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`Wiz’s incomplete production of relevant JIRA documents.
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`Defendant Wiz, Inc.’s Issues For Teleconference:
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`1.
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`2.
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`Plaintiff’s responses to Defendant’s Interrogatory Nos. 2 and 4.
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`Plaintiff’s response to Defendant’s RFP No. 54.
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`The following attorneys, including at least one Delaware Counsel and at least one
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`Lead Counsel per party, participated in one or more verbal meet-and-confers by telephone on the
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`following dates: May 21, 2024, May 23, 2024, and June 3, 2024.
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`Case 1:23-cv-00758-JLH Document 95 Filed 07/02/24 Page 2 of 2 PageID #: 2123
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`
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`Delaware Counsel:
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` Orca: Rodger Smith and Cameron Clark (Morris, Nichols, Arsht & Tunnell);
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` Wiz: Christine Haynes and Fred Cottrell (Richards, Layton & Finger)
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`Lead Counsel:
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` Orca: Blake Davis, Chris Henry, Krissy McKenna, Lucas Lonergan, and Peter
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`Hoffman (Latham & Watkins);
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` Wiz: Caty Lacey and Praatika Prasad (Wilson Sonsini)
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`The parties are available for a teleconference on the following dates: July 11,
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`July 16, or July 17 after 1:00 pm ET.
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`
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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)
`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
`
`July 2, 2024
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`
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`RICHARD, LAYTON & FINGER, P.A.
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`/s/ Kelly E. Farnan
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`
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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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`2
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