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`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`§
`2:22-md-03034-TGB
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`HON. TERRENCE G. BERG
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`ORDER
`COMMISSION DIRECTING THE TAKING ABROAD OF VOLUNTARY
`ORAL DEPOSITIONS OF JAPANESE WITNESSES
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`TO: ANY COUNSUL OR VICE COUNSUL OF THE UNITED
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`2:22-cv-11406-TGB
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`HON. TERRENCE G. BERG
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`JURY TRIAL DEMANDED
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`NEO WIRELESS, LLC,
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`TOYOTA MOTOR CORPORATION,
`TOYOTA MOTOR NORTH
`AMERICA, INC., TOYOTA MOTOR
`SALES, U.S.A., INC., & TOYOTA
`MOTOR ENGINEERING &
`MANUFACTURING NORTH
`AMERICA, INC., & TOYOTA
`MOTOR CREDIT CORPORATION,
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`Plaintiff,
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`v.
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`Defendants.
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`STATES, UNITED STATES CONSULATE OSAKA, JAPAN or UNITED
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`STATES EMBASSY TOKYO, JAPAN:
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`Case 2:22-md-03034-TGB ECF No. 183, PageID.11290 Filed 09/28/23 Page 2 of 3
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`Upon the Application of Plaintiff Neo Wireless, LLC pursuant to Article 17
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`of the United States-Japan Consular Convention,
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`You have been duly appointed and you are hereby authorized to take the oral
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`depositions at the United States Consulate in Osaka, Japan or the United States
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`Embassy Tokyo, Japan, of the following witnesses who will appear voluntarily:
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`Satoshi Hata, employee of Toyota Motor Corporation, 1 Toyota-Cho, Toyota City,
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`Aichi Prefecture 471-8571, Japan.
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`The depositions are scheduled to commence on or about October 25, 2023 at
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`8:45 a.m. and terminate on or about October 26, 2023 at 4:00 p.m., and to mark
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`any documentary exhibits in connection therewith.
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`Counsel for Defendants who will participate in the depositions in person at
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`the United States Consulate is Matthew Satchwell. Counsel for Defendants who
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`may participate in the depositions virtually via remote audio and/or
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`videoconference are Paul Steadman, Brian Erickson, Dawn Jenkins, Shuzo
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`Maruyama, Ankur Desai, Monica De Lazzari, Chris Katsantonis, and Farris
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`Matariyeh.
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`Counsel for the Plaintiff who will participate in the depositions are Jason D.
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`Cassady, Christopher S. Stewart, Daniel R. Pearson, Hamad M. Hamad, Bailey A.
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`Blaies, James F. Smith, and James Yang. One of the aforementioned attorneys will
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`participate in the depositions in-person at the United States Consulate, the
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`2
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`Case 2:22-md-03034-TGB ECF No. 183, PageID.11291 Filed 09/28/23 Page 3 of 3
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`remainder, may participate in the depositions virtually via remote audio and/or
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`videoconference.
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`The proceedings will be reported, videotaped and/or interpreted by Planet
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`Depos – American Realtime Court Reporters: Mary Allred, Jade King, Charlotte
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`Lacey, Mark McClure, Jason Meadors, Giselle Mitchell, and Kadi Harmon
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`(reporters); Trevor Price, Scott Yuken, Christie Jeon, Jeremy Dineen, Linda Fleet,
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`Wendy Viner, and Joe Viner (videographers); Jeremy Dineen, Scott Yuken, Christie
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`Jeon, Linda Fleet, Wendy Viner, and Joe Viner (technicians); and Naoko Selland,
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`Mike Sekine, Hanako Kaku, Tobias “Toby” Rushbrook, and Yoshiko Iga
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`(interpreters). The proceedings will also be interpreted by Ai Miyake.
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`Please cause the testimony of said witnesses to be reduced to writing and the
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`depositions signed by said witnesses and annex said deposition testimony your
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`commission and close the same under your seal and make return thereof to this
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`Court with all convenient speed.
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`IT IS SO ORDERED.
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`DATE: September 28, 2023
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`/s/Terrence G. Berg_____________
`Hon. Terrence G. Berg
`United States District Judge
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`3
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