`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`MAXELL, LTD.’S NOTICE OF WITHDRAWAL OF DEPOSITION NOTICE ON ANDREW
`STEIN (SUBJECT OF APPLE’S MOTION FOR PROTECTIVE ORDER (D.I. 116))
`
`Plaintiff Maxell, Ltd. writes to provide notice that it withdraws its Rule 30(b)(1) notice of
`
`deposition for Andrew Stein. Following the Court’s Order on Maxell’s Motion to Compel (D.I. 126),
`
`Maxell reached out to Apple stating that, subject to Apple’s compliance with the Court’s Order and service
`
`of a response to Interrogatory No. 6, Maxell would not seek the deposition of Andrew Stein. Because it
`
`appears, in view of recent communications, that Apple may continue to withhold relevant information
`
`despite the Court’s Order, Maxell reserves the right to re-notice Mr. Stein’s deposition in the future in the
`
`event Apple is not forthcoming with the information requested by Interrogatory No. 6.
`
`Given Maxell’s withdrawal of its deposition notice, Apple’s Motion for a Protective Order (D.I.
`
`116) is moot.1
`
`
`
`
`
`
`1 Maxell proposed filing a joint notice with the Court regarding Apple’s Motion for a Protective
`Order (D.I. 116), but has not heard back from Apple regarding this proposal. Maxell thus proceeded with
`the current notice so that the Court may avoid any unnecessary expenditure of resources in considering
`Apple’s Motion.
`
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 132 Filed 11/18/19 Page 2 of 4 PageID #: 5557
`
`Dated: November 18, 2019
`
`By:
`
`/s/ Jamie B. Beaber
`Geoff Culbertson
`Kelly Tidwell
`Patton, Tidwell & Culbertson, LLP
`2800 Texas Boulevard (75503)
`Post Office Box 5398
`Texarkana, TX 75505-5398
`Telephone: (903) 792-7080
`Facsimile: (903) 792-8233
`gpc@texarkanalaw.com
`kbt@texarkanalaw.com
`
`Jamie B. Beaber
`Alan M. Grimaldi
`Kfir B. Levy
`James A. Fussell, III
`Baldine B. Paul
`Tiffany A. Miller
`Saqib J. Siddiqui
`Bryan C. Nese
`William J. Barrow
`Alison T. Gelsleichter
`Clark S. Bakewell
`MAYER BROWN LLP
`1999 K Street, NW
`Washington, DC 20006
`Telephone: (202) 263-3000
`Facsimile: (202) 263-3300
`jbeaber@mayerbrown.com
`agrimaldi@mayerbrown.com
`klevy@mayerbrown.com
`jfussell@mayerbrown.com
`bpaul@mayerbrown.com
`tmiller@mayerbrown.com
`ssiddiqui@mayerbrown.com
`bnese@mayerbrown.com
`wbarrow@mayerbrown.com
`agelsleichter@mayerbrown.com
`cbakewell@mayerbrown.com
`
`Robert G. Pluta
`Amanda Streff Bonner
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`(312) 782-0600
`
`
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 132 Filed 11/18/19 Page 3 of 4 PageID #: 5558
`
`rpluta@mayerbrown.com
`asbonner@mayerbrown.com
`
`Counsel for Plaintiff Maxell, Ltd.
`
`
`
`3
`
`
`
`Case 5:19-cv-00036-RWS Document 132 Filed 11/18/19 Page 4 of 4 PageID #: 5559
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 18th day of November, 2019, with a copy of this document
`via the Court’s electronic CM/ECF system.
`
`
`
`
`/s/ Jamie B. Beaber
`Jamie B. Beaber
`
`
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
