`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`JURY TRIAL DEMANDED
`
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`
`UNOPPOSED MOTION FOR ENTRY OF STIPULATED
`SUPPLEMENTAL PROTECTIVE ORDER
`Plaintiff Neo Wireless and Intel Corporation, a subpoenaed non-party to this
`
`action, by and through their respective counsel, hereby file this Unopposed Motion
`
`for Entry of a Stipulated Supplemental Protective Order. The Supplemental
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`Protective Order relates to the confidential information of third-party Intel
`
`Corporation that will be produced in this action. As a compromise to avoid a
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`dispute with the Court, and given the unique circumstances of Intel’s relationship
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`to this case and the small amount of discovery at issue, the relevant parties have
`
`agreed on the proposed order attached hereto as Exhibit A. Neo Wireless
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`respectfully requests that the Court enter the proposed Stipulated Supplemental
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`Protective Order as attached hereto. Defendant Tesla Inc. does not oppose this
`
`motion.
`
`
`
`1
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`
`
`Case 2:22-md-03034-TGB ECF No. 208, PageID.11804 Filed 12/21/23 Page 2 of 2
`
`DATED: December 21, 2023
`
`Respectfully submitted,
`
`
`
`/s/ Megan Whyman Olesek
`Megan Whyman Olesek
`California Bar No. 191218
`Email: olesek@turnerboyd.com
`TURNER BOYD SERAPHINE LLP
`155 Bovet Road, Suite 750
`San Mateo, California 94402
`Telephone: (650) 265-6109
`
`Thomas W. Cranmer (P25252)
`Email: cranmer@millercanfield.com
`Miller, Canfield, Paddock and Stone,
`P.L.C.
`840 West Long Lake Road
`Suite 150
`Troy, Michigan 48098-6358
`Telephone: (248) 267-3381
`
`COUNSEL FOR NON-PARTY
`INTEL CORPORATION
`
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`Texas State Bar No. 24045625
`Email: jcassady@caldwellcc.com
`Christopher S. Stewart
`Texas State Bar No. 24079399
`Email: cstewart@caldwellcc.com
`CALDWELL CASSADY CURRY P.C.
`2121 N. Pearl St., Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 888-4848
`Facsimile: (214) 888-4849
`
`Jaye Quadrozzi (P71646)
`Email: quadrozzi@youngpc.com
`YOUNG, GARCIA & QUADROZZI, PC
`2775 Stansbury Blvd., Suite 125
`Farmington Hills, Michigan 48334
`Telephone: (248) 353-8620
`
`ATTORNEYS FOR PLAINTIFF
`NEO WIRELESS LLC
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on December 21, 2023, the foregoing document
`
`was filed electronically with the Clerk of Court using the CM/ECF system, which
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`will send notification of such filing to all attorneys of record.
`
`
`
`
`
`
`
`
`
`/s/ Jason D. Cassady
`Jason D. Cassady
`
`
`
`2
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`
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