Case 5:16-cv-00179-RWS Document 287-32 Filed 08/07/18 Page 1 of 5 PageID #: 16880
`
`
`
`
`Exhibit 29
`
`
`
`
`
`
`
`
`
`
`

`

`Case 5:16-cv-00179-RWS Document 287-32 Filed 08/07/18 Page 2 of 5 PageID #: 16881
`
`Bakewell, Clark S.
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Levy, Kfir B.
`Monday, May 14, 2018 5:26 PM
`Wisnia, Howard N.
`ZTE_Hitachi; Moore, Steve; Brian Craft; Beaber, Jamie B.; Miller, Tiffany A.; Fussell, Tripp;
`Geoff Culbertson; US-CLIENT-HM-ZTE-Service
`RE: Maxell v ZTE -- Exhibit Lists
`
`Howard,
`
`Thanks for the call. I think it s was production. Here are the dates we agreed just now:
`
`
`May 16: exchange revised initial exhibit lists (limited to 200 exhibit s per side); deposition designation
`objections; deposition counter-designations
`
`May 20: exchange rebuttal exhibit lists
`
`May 22: exchange objections to revised initial exhibit lists and rebuttal exhibit lists; deposition counter-
`designation objections; counter-counter-designations (if any)
`
`May 24: meet and confer regarding objections to exhibit lists and deposition designations
`
`May 25: submission of pretrial order
`
`
`We also agreed to keep communications open regarding objections to exhibit lists and deposition designations and,
`should the parties narrow their lists/objections, we will submit revised lists to the court in advance of the pretrial
`conference, which takes place June 7.
`
`Please confirm this is your understanding of our agreement.
`
`Thanks,
`
`Kfir B. Levy
`Partner | Intellectual Property
`Mayer ♦ Brown
`Direct Dial - 202.263.3136
`klevy@mayerbrown.com
`
`
`From: Wisnia, Howard N. [mailto:howard.wisnia@pillsburylaw.com]
`Sent: Monday, May 14, 2018 1:00 PM
`To: Levy, Kfir B.
`Cc: ZTE_Hitachi; Moore, Steve; Brian Craft; Beaber, Jamie B.; Miller, Tiffany A.; Fussell, Tripp; Geoff Culbertson
`Subject: RE: Maxell v ZTE -- Exhibit Lists
`
`Please note the following dialing information:
`
`
`
` Start the Audio Conference
`Dial-In:
`1 (866) 244-1129 US Toll Free
`1 (847) 413-3720 US Toll
`
`544 3120#
`Passcode:
`
`
`For a current list of available local and international freephone telephone numbers, CLICK
`
`
`
`1
`
`

`

`Case 5:16-cv-00179-RWS Document 287-32 Filed 08/07/18 Page 3 of 5 PageID #: 16882
`
`HERE
`
`
`
`
`
`
`
`
`
`
`
`
`From: Levy, Kfir B. <KLevy@mayerbrown.com>
`Sent: Monday, May 14, 2018 9:58 AM
`To: Wisnia, Howard N. <howard.wisnia@pillsburylaw.com>
`Cc: ZTE_Hitachi <ZTEHitachi@Pillsburylaw.com>; Moore, Steve <steve.moore@pillsburylaw.com>; Brian Craft
`<BCraft@FindlayCraft.com>; Beaber, Jamie B. <JBeaber@mayerbrown.com>; Miller, Tiffany A.
`<TMiller@mayerbrown.com>; Fussell, Tripp <JFussell@mayerbrown.com>; Geoff Culbertson <gpc@texarkanalaw.com>
`Subject: RE: Maxell v ZTE -- Exhibit Lists
`
`
`Howard,
`
`
` pm pacific/5 pm eastern works for me. Can you please circulate dial-in information?
`
` 2
`
`
`
`Thanks,
`
`
`Kfir B. Levy
`Partner | Intellectual Property
`Mayer ♦ Brown
`Direct Dial - 202.263.3136
`klevy@mayerbrown.com
`
`
`
`From: Wisnia, Howard N. [mailto:howard.wisnia@pillsburylaw.com]
`Sent: Monday, May 14, 2018 12:57 PM
`To: Levy, Kfir B.
`Cc: ZTE_Hitachi; Moore, Steve; Brian Craft; Beaber, Jamie B.; Miller, Tiffany A.; Fussell, Tripp; Geoff Culbertson
`Subject: RE: Maxell v ZTE -- Exhibit Lists
`
`
`Hi Kfir,
`
`I’m generally available any time after 1:30pm California time today. Let me know what works. I’ll propose 2pm
`California time. Thanks, Howard
`
`
`
`From: Levy, Kfir B. <KLevy@mayerbrown.com>
`Sent: Friday, May 11, 2018 3:48 PM
`To: Wisnia, Howard N. <howard.wisnia@pillsburylaw.com>
`Cc: ZTE_Hitachi <ZTEHitachi@Pillsburylaw.com>; Moore, Steve <steve.moore@pillsburylaw.com>; Brian Craft
`<BCraft@FindlayCraft.com>; Beaber, Jamie B. <JBeaber@mayerbrown.com>; Miller, Tiffany A.
`<TMiller@mayerbrown.com>; Fussell, Tripp <JFussell@mayerbrown.com>; Geoff Culbertson <gpc@texarkanalaw.com>
`Subject: Re: Maxell v ZTE -- Exhibit Lists
`
`
`Howard,
`
`
`We agree. No exchange tonight; we’ll make the exchange Wednesday. Please let us know when on Monday you’re
`available to discuss limits.
`
`
`Thanks,
`Kfir
`
`On May 11, 2018, at 4:44 PM, Wisnia, Howard N. <howard.wisnia@pillsburylaw.com> wrote:
`
`2
`
`

`

`Case 5:16-cv-00179-RWS Document 287-32 Filed 08/07/18 Page 4 of 5 PageID #: 16883
`
`Hi Kfir,
`
`
`We agree the parties need to narrow the lists. As we just discussed, ZTE proposes we move all the
`items due today until Weds. on Monday we can have a call to agree on the exact limits he parties will
`agree to. Please confirm. Thanks, Howard
`
`Best Regards, Howard
`
`
`
`Howard N. Wisnia | Partner
`Pillsbury Winthrop Shaw Pittman LLP
`501 West Broadway, Suite 1100 | San Diego, CA 92101-3575
`t 619.544.3120 | m 858.245.1591
`howard.wisnia@pillsburylaw.com | website bio
`
`
`On May 11, 2018, at 7:03 AM, Levy, Kfir B. <KLevy@mayerbrown.com> wrote:
`
`Counsel,
`
`In light of the court’s comments following the hearing yesterday, we propose that the parties revise—
`and substantially reduce—their respective exhibit lists. The court made clear that submission of exhibit
`lists with over 500 exhibits will not be tolerated.
`
`
`Therefore, we propose the parties exchange revised exhibit lists (to include rebuttal exhibits, too) on
`Wednesday, May 16. The parties should endeavor to limit their respective lists to no more than 200
`exhibits, including rebuttal exhibits. We also propose the parties provide their objections to the exhibit
`lists on May 22. This would replace the current schedule, but for exhibits only. The schedule for the
`remaining pretrial disclosures would remain unchanged.
`
`In light of today’s deadline, please let us know as soon as possible if you agree. If you do not agree, we
`will ultimately raise the issue of ZTE’s 500+ exhibit list with the court, but we believe this proposal is
`workable and we are hopeful that we need not reach out to the court to resolve this particular issue.
`
`
`We are available to discuss by phone if that would be helpful.
`
`
`Thanks,
`
`
`Kfir B. Levy
`Partner | Intellectual Property
`Mayer ♦ Brown
`klevy@mayerbrown.com
`Direct Dial - 202.263.3136
`Fax - 202.263.5209
`1999 K Street, N.W.
`Washington, DC 20006
`www.mayerbrown.com
`
`
`
`__________________________________________________________________________
`
`
`
`3
`
`

`

`Case 5:16-cv-00179-RWS Document 287-32 Filed 08/07/18 Page 5 of 5 PageID #: 16884
`
`This email and any files transmitted with it are intended solely for the use of the individual or entity to
`whom they are addressed. If you have received this email in error please notify the system manager. If
`you are not the named addressee you should not disseminate, distribute or copy this e-mail.
`
`
`
`
`The contents of this message, together with any attachments, are intended only for the use of the
`individual or entity to which they are addressed and may contain information that is legally
`privileged, confidential and exempt from disclosure. If you are not the intended recipient, you
`are hereby notified that any dissemination, distribution, or copying of this message, or any
`attachment, is strictly prohibited. If you have received this message in error, please notify the
`original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel: 800-477-0770, Option
`1, immediately by telephone or by return E-mail and delete this message, along with any
`attachments, from your computer. Thank you.
`
`
`
`
`
`The contents of this message, together with any attachments, are intended only for the use of the individual or
`entity to which they are addressed and may contain information that is legally privileged, confidential and
`exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination,
`distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this
`message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel:
`800-477-0770, Option 1, immediately by telephone or by return E-mail and delete this message, along with any
`attachments, from your computer. Thank you.
`
`
`
`
`
`
`The contents of this message, together with any attachments, are intended only for the use of the individual or
`entity to which they are addressed and may contain information that is legally privileged, confidential and
`exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination,
`distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this
`message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel:
`800-477-0770, Option 1, immediately by telephone or by return E-mail and delete this message, along with any
`attachments, from your computer. Thank you.
`
`
`
`
`4
`
`