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`Exhibit 21 16
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`Exhibit 2116
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`1
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`CA NO. 12-1701-RGA
`12-1702-RGA
`12-1703-RGA
`September 16, 2014
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`1:36 o'clock p.m.
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`: : : : : : : : : :
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`CALLWAVE COMMUNICATION LLC,
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`Plaintiff,
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`v.
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`AT&T MOBILITY LLC, et al.,
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`Defendants,
`.............................
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`TRANSCRIPT OF DISCOVERY DISPUTE
`BEFORE THE HONORABLE RICHARD G. ANDREWS
`UNITED STATES DISTRICT JUDGE
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`APPEARANCES:
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`For Plaintiff:
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`PEPPER HAMILTON LLP
`BY: EDMOND D. JOHNSON, ESQ
`BY: GREGORY S. BISHOP, ESQ
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`For Defendants:
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`BY: WILLIAM D. BELANGER, ESQ
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`MORRIS, NICHOLS, ARSHT & TUNNELL
`BY: KAREN JACOBS, ESQ
`-and-
`DENTONS LLP
`BY: KIRK R. RUTHENBERG, ESQ
`For Defendant Sprint
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`CONNOLLY GALLAGHER LLP
`BY: ARTHUR G. CONNOLLY, III, ESQ
`-and-
`DENTONS LLP
`BY: KIRK R. RUTHENBERG, ESQ
`For Defendant T-Mobile
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`SEITZ ROSS ARONSTAM & MORITZ
`BY: BENJAMIN J. SCHLADWEILER, ESQ
`For Defendant AT&T
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`MORRIS, NICHOLS, ARSHT & TUNNELL
`BY: PAUL SAINDON, ESQ
`For Defendant Google
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`Court Reporter:
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`LEONARD A. DIBBS
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`5
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`of that indemnification or other communications about
`indemnification.
`For example, let's say that AT&T, we heard this morning
`that they're only partially indemnifying, that Location Labs is
`only partially indemnifying AT&T.
`THE COURT: Okay. So, let's say they are only
`partially indemnifying.
`What do you think you might find in these letters that
`you aren't going to get in your other -- wait. Hold on a
`second.
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`So, are you not producing these additional things that
`Mr. Bishop is talking about, because they're privileged, or
`they're irrelevant, or they don't exist, or some combination of
`the three?
`MR. RUTHENBERG: Some combination of that, your Honor.
`No. 1, I am not aware of any communications after the
`acceptance of the defense by Location Labs regarding
`indemnification, between Location Labs and any of the
`defendants.
`THE COURT: And if there were interim communications
`before it was accepted, instead of, here's our request, and
`here's an acceptance, if there was a some back and forth before
`Location Labs accepted, is that what you have committed to
`provide?
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`MR. RUTHENBERG: We are willing to produce that, as
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