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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`Plaintiff,
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`Defendant.
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`Case No. 5:19-cv-00036-RWS
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`JURY TRIAL DEMANDED
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`MAXELL, LTD.,
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`v.
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`APPLE INC.,
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`PLAINTIFF MAXELL, LTD.’S PRETRIAL OBJECTIONS
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`Pursuant to the Court’s Amended Docket Control Order (Dkt. No. 545), Plaintiff Maxell,
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`Ltd. (“Plaintiff” or “Maxell”) hereby submits its pretrial objections.
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`Attached at Exhibit A is a listing of Maxell’s objections to Defendant Apple Inc.’s
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`(“Apple”) proposed trial exhibits. Attached at Exhibit B is a listing of Maxell’s objections to
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`Apple’s deposition designations.
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`As set forth in the Joint Motion to Partially Amend Docket Control Order (D.I. 542), and
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`reflected in the resulting Amended Docket Control Order (D.I. 545), the parties previously agreed
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`to a schedule to further narrow their objections to trial exhibits and deposition designations in
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`advance of an in-person meet and confer scheduled to occur on November 11, 2020. Following
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`such meeting, the parties will jointly notify the Court of the status and proposed steps for resolving
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`any remaining pretrial objections. At this time, Maxell does not anticipate the need for the Court
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`to resolve its pretrial objections at the November 12, 2020 pretrial conference.
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`In view of the foregoing, Maxell reserves the right to withdraw or amend these objections
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`based on continuing meet and confers between the parties.
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`PUBLIC VERSION
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 562 Filed 11/05/20 Page 2 of 4 PageID #: 29957
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`Dated: November 3, 2020
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`/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
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`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
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`Robert G. Pluta
`Amanda Streff Bonner
`MAYER BROWN LLP
`71 S. Wacker Drive
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`2
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 562 Filed 11/05/20 Page 3 of 4 PageID #: 29958
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`Chicago, IL 60606
`(312) 782-0600
`rpluta@mayerbrown.com
`asbonner@mayerbrown.com
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`Counsel for Plaintiff Maxell, Ltd.
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`3
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 562 Filed 11/05/20 Page 4 of 4 PageID #: 29959
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who are deemed to have consented to
`electronic service are being served this 3rd day of November, 2020, with a copy of this document
`via electronic mail pursuant to Local Rule CV-5(d).
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`/s/ Jamie B. Beaber
`Jamie B. Beaber
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`PUBLIC VERSION
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