Argenti, Matthew
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Eliot.Williams@bakerbotts.com
`Tuesday, July 07, 2015 4:29 PM
`Rosato, Michael
`Argenti, Matthew; hop.guy@bakerbotts.com; brad.bowling@bakerbotts.com
`RE: Echostar/Hughes v. Caltech: IPR2015-00059
`
`Michael:
`
`We have attempted to schedule the deposition of Ms. Fradenburg, but she is unwilling to appear
`voluntarily. To the extent Patent Owner would like her deposition, we suggest that you request issuance of a
`subpoena to compel her deposition. See Marvell v. IV, IPR2014-00553, Paper 28 (April 8, 2015). We also
`question whether the authenticity and publication date of the reference at issue is genuinely in dispute in this
`proceeding.
`
`Regarding Dr. Pfister’s availability, we can make him available at our offices in Palo Alto on July 22nd. As that
`would be slightly outside the typical time for completing the deposition, we would be amenable to a slight
`adjustment to the due dates in the current schedule. Let us know if you would like to propose such a
`modification.
`
`Regards,
`
`Eliot D. Williams
`■
`BAKER BOTTS LLP
`1001 Page Mill Road
`Bldg. One, Ste. 200
`Palo Alto, CA 94304-1007
`+1 650 739-7511 (Direct Dial)
`+1 650 739-7611 (Fax)
`
`
`From: Rosato, Michael [mailto:mrosato@wsgr.com]
`Sent: Friday, June 12, 2015 3:42 PM
`To: Williams, Eliot D.
`Cc: Argenti, Matthew; Guy, Hop
`Subject: Echostar/Hughes v. Caltech: IPR2015-00059
`
`Eliot,
`
`We would like to schedule cross-examination of the witnesses who provided affidavit testimony in support of the
`EchoStar/Hughes petition. As you know, Rule 42.53(d)(2) prescribes that the party requesting cross-examination
`testimony choose the order in which the witnesses are to be cross-examined. As such, we will cross the witnesses in the
`following order, beginning with Ms. Fradenburg.
`
`
`• Robin Fradenburg
`• Dr. Pfister
`
`
`Please provide us with dates on which the witnesses can be made available for cross-examination. You’ll recall that the
`period for cross concludes on July 21st based on the scheduling order.
`
`1
`
`CALTECH - EXHIBIT 2026
`
`

`
`
`Best regards,
`
`Michael T Rosato
`Wilson Sonsini Goodrich & Rosati
`[o] 206.883.2529 | [f] 206.883.2699
`mrosato@wsgr.com
`
`
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`2