`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MYPAQ HOLDINGS LTD.,
`
`CIVIL ACTION NO. 6:21-CV-00933-ADA
`
`Plaintiff,
`
`v.
`
`DELL TECHNOLOGIES INC. and
`DELL INC.,
`
`JURY TRIAL DEMANDED
`
`Defendants.
`
`PLAINTIFF’S NOTICE OF DEPOSITION OF ANDY SULTENFUSS
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(1) of the Federal Rules of Civil
`
`Procedure, Plaintiff MyPAQ Holdings Ltd. (“MyPAQ” or “Plaintiff”) will take the deposition of Andy
`
`Sultenfuss by oral examination.
`
`The deposition will take place beginning on Friday, March 18, 2022, at 1:00 p.m. CT. The
`
`deposition will be conducted virtually through a private video conference, the credentials of which
`
`will be provided in advance, and will continue from day to day until completed. The deposition shall
`
`be taken before an officer authorized to take oaths and shall be recorded by a stenographer and by
`
`videotape. Plaintiff reserves the right to use LiveNote or other technology for real-time transcription
`
`of the testimony. The deposition will be taken for the purpose of discovery, to perpetuate testimony
`
`for use at trial, and for all other purposes permitted under the Federal Rules of Civil Procedure.
`
`The procedures for attending the remote deposition are below and all participants should
`
`contact Lexitas directly for any technical questions or assistance.
`
`1.
`
`Participants need a computer equipped with a webcam and a high-speed, reliable
`
`internet connection.
`
`2.
`
`In advance of the deposition, counsel for Plaintiff or Lexitas will provide a link for the
`
`remote deposition.
`
`MyPAQ, Exhibit 2011
`IPR2022-00311
`Page 1 of 4
`
`
`
`3.
`
`Immediately before the deposition, participants should click the link to automatically
`
`connect to a secure meeting via the internet.
`
`4.
`
`Participants should be prepared to connect to audio via telephone with clear reception
`
`in the event transmission of audio by internet is unclear.
`
`5.
`
`Participants should mute their microphone unless actively participating to reduce
`
`interference, echo, and ambient noise.
`
`6.
`
`Deposition exhibits will be presented and exchanged electronically.
`
`
`
` 2
`
`MyPAQ, Exhibit 2011
`IPR2022-00311
`Page 2 of 4
`
`
`
`Dated: February 16, 2022
`
`
`Respectfully submitted,
`
`By: /s/ Krisina J. Zuñiga
`
`Charles Ainsworth (Texas 00783521)
`Robert Christopher Bunt (Texas 00787165)
`PARKER, BUNT & AINSWORTH, P.C.
`100 E. Ferguson, Suite 418
`Tyler, Texas 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
`
`Alfonso G. Chan (Texas 24012408)
`Michael W. Shore (Texas 18294915)
`Halima Shukri Ndai (Texas 24105486)
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, Texas 75202
`Tel: (214) 593-9110
`Fax: (214) 593-9111
`achan@shorechan.com
`mshore@shorechan.com
`hndai@shorechan.com
`
`Brian D. Melton (Texas 24010620)
`Krisina J. Zuñiga (Texas 24098664)
`Scott T. Glass (Texas 24121287)
`SUSMAN GODFREY LLP
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Tel: (713) 651-9366
`Fax: (713) 654-6666
`bmelton@susmangodfrey.com
`kzuniga@susmangodfrey.com
`sglass@susmangodfrey.com
`
`Steven M. Shepard (New York 5291232)
`SUSMAN GODFREY LLP
`1301 Avenue of the Americas, 32nd Floor
`New York, New York 10019
`Tel: (212) 336-8330
`Fax: (212) 336-8340
`sshepard@susmangodfrey.com
`
`COUNSEL FOR PLAINTIFF
`MYPAQ HOLDINGS LTD.
`
`
`
`
` 3
`
`
`
`MyPAQ, Exhibit 2011
`IPR2022-00311
`Page 3 of 4
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that I served counsel of record on Wednesday, February 16, 2022, with a copy
`
`of this document via electronic mail.
`
`
`
`/s/ Krisina J. Zuñiga
`Krisina J. Zuñiga
`SUSMAN GODFREY LLP
`
`
`
`
`
`
` 4
`
`MyPAQ, Exhibit 2011
`IPR2022-00311
`Page 4 of 4
`
`
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