Case 1:13-cv-00800-SS Document 48 Filed 05/07/14 Page 1 of 4
`
`
` CROSSROADS EXHIBIT 2020
` Cisco Systems et al v Crossroads Systems, Inc.
` IPR2014-01544
`
`(cid:20)(cid:3)(cid:82)(cid:73)(cid:3)(cid:23)
`
`

`

`Case 1:13-cv-00800-SS Document 48 Filed 05/07/14 Page 2 of 4
`
`•
`
`v.
`
`NETAPP, INC.
`
`Defendant.
`
`v.
`
`QUANTUM CORPORATION
`
`Defendant.
`
`§
`§
`§ C.A. NO. 1:14-cv-00149-SS
`§
`§
`
`§
`§
`§ C.A. NO. 1:14-cv-00150-SS
`§
`§
`
`AGREED ORDER GRANTING
`JOINT MOTION TO COORDINATE CASES FOR DISCOVERY
`
`The Court, having considered the parties' Joint Motion to Coordinate Cases for
`
`Discovery, finds that the motion is well-taken and should be, and is hereby GRANTED.
`
`It is therefore, ORDERED that discovery in the above numbered cases shall be
`
`coordinated . The discovery limits below shall apply to the above-captioned cases. These limits
`
`may be modified by agreement of the Parties or upon a showing of good cause. All parties retain
`
`their rights to seek additional discovery beyond the limits provided here.
`
`Interrogatories.
`
`Plaintiff may serve up to
`
`ten (10) common
`
`interrogatories on
`
`Defendants, which each Defendant Affiliate Group shall answer individually, and Plaintiff may
`
`serve an additional fifteen (15) individual or specific interrogatories on each Defendant Affiliate
`
`Group. 1 Defendants, jointly, may serve up to ten (10) common interrogatories on Plaintiff, and
`
`each Defendant Affiliate Group may serve an additional fifteen (15) individual or specific
`
`interrogatories on Plaintiff.
`
`1 Each of the following comprises a "Defendant Affiliate Group": (1) Dot Hill Systems Corp. ; (2)
`Oracle Corporation; (3) Dell Inc.; (4) Huawei Technologies Co., Ltd., Huawei Enterprise USA,
`Inc. , and Huawei Technologies USA, Inc. ; (5) Tandberg Data Corporation; (6) Cisco Systems,
`Inc.; (7) Netapp, Inc.; and (8) Quantum Corporation.
`
`2
`
`(cid:21)(cid:3)(cid:82)(cid:73)(cid:3)(cid:23)
`
`

`

`--------- ------------------- - - - -···-----·-·····--··-
`Case 1:13-cv-00800-SS Document 48 Filed 05/07/14 Page 3 of 4
`
`•
`
`•
`
`Requests for Admission. Except for authentication purposes, Plaintiff may serve up to
`
`twenty-five (25) common requests for admission on Defendants, which each Defendant Affiliate
`
`Group shall answer individually, and an additional fifteen (15) individual or specific requests for
`
`admission on each Defendant Affiliate Group. Defendants, jointly, may serve up to twenty-five
`
`(25) common requests for admission on Plaintiff, and each Defendant Affiliate Group may serve
`
`an additional fifteen (15) individual or specific requests for admission on Plaintiff.
`
`There is no limit on the number of requests for admission the parties may serve to
`
`establish authenticity of documents.
`
`Overall Deposition Limits. For all depositions other than expert depositions, Plaintiff
`
`may take up to forty ( 40) hours of deposition testimony of each Defendant Affiliate Group
`
`(which
`
`includes both Rule 30(b)(6) depositions and Rule 30(b)(l) depositions of party
`
`employees).
`
`In addition, Plaintiff is entitled to take forty ( 40) hours of non party deposition
`
`testimony. Defendants may jointly take up to fifty (50) hours of deposition testimony of Plaintiff
`
`and individually take up to twenty (20) additional hours of deposition testimony of Plaintiff
`
`(which
`
`includes both Rule 30(b)(6) depositions and Rule 30(b)(l) depositions of party
`
`employees, but does not include the depositions of inventors), and jointly take up to fifty (50)
`
`hours of non party deposition testimony. Depositions, including depositions on written questions,
`
`of custodians of business records for third parties are also permitted but are not included in the
`
`limit on deposition hours per side set forth above.
`
`Duration of Depositions. Unless otherwise specified below, each deposition shall be
`
`limited to one day of seven (7) hours on the record. For inventor depositions, Defendants as a
`
`group will be limited to ten (10) deposition hours of each inventor in his individual capacity as
`
`an inventor (excluding deposition time as a 30(b)(6) witness). Each deposition of inventors or
`
`3
`
`(cid:22)(cid:3)(cid:82)(cid:73)(cid:3)(cid:23)
`
`

`

`Case 1:13-cv-00800-SS Document 48 Filed 05/07/14 Page 4 of 4
`
`•
`
`30(b)(6) witnesses will be taken on consecutive days and shall not continue for more than seven
`
`(7) hours on the record each day. 2 Any deposition of an expert witness will be limited to seven
`
`(7) hours per witness per report.
`
`In addition to the seven (7) hours per report, if an expert
`
`witness issues a report or expresses an opinion addressing infringement or damages issues for
`
`multiple Defendants in this action, for that report, he/she may be deposed up to an additional two
`
`(2) hours for each Defendant beyond the first seven (7) hours. For each of the durational limits
`
`provided here, pursuant to Fed. R. Civ. P. 30, additional time consistent with Rule 26(b)(2) will
`
`be allowed if needed to fairly examine the deponent.
`
`I+
`SIGNED this ~day of
`
`'Jn4VJ
`
`'2014.
`
`lJl~~
`
`UNITED STATES DISTRICT JUDGE
`
`2 "For purposes of this durational limit, the deposition of each person designated under Rule
`30(b)(6) should be considered a separate deposition." 2000 Notes to Fed. R. Civ. P. 30, ~ 3.
`
`4
`
`(cid:23)(cid:3)(cid:82)(cid:73)(cid:3)(cid:23)
`
`