`EQUIPMENT LLC,
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`Plaintiff,
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`v.
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`LG ELECTRONICS INC., ET AL.,
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`Civil Action No. 6:14-cv-982-JRG
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`Case 6:14-cv-00982-KNM Document 82 Filed 06/19/15 Page 1 of 3 PageID #: 533
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`Defendants.
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`AT&T MOBILITY LLC’S MOTION FOR
`ADOPTION AND ENTRY OF DISCOVERY ORDER
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`In accordance with the Court’s Order of June 15, 2015 (Dkt. 62), AT&T Mobility LLC
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`(“AT&T”) hereby submits its proposed Discovery Order, attached hereto as Exhibit A. AT&T’s
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`proposed Discovery Order is largely the same as the Discovery Order proposed by the other
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`parties, but with some modifications to the expert depositions section 5(e). Attached hereto as
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`Exhibit B is a redline comparison showing the differences between AT&T’s proposed Discovery
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`Order and the Discovery Order submitted by the other parties. While AT&T’s proposal does not
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`vary significantly from the proposal submitted by the other parties, AT&T submits that its
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`proposal more adequately addresses the number of disparate patents in this case, and reflects the
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`minimum sufficient amount of time for Defendants to depose Plaintiff’s experts. In particular,
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`AT&T proposes the following limits be established for Defendants to collectively depose
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`Plaintiff’s experts:
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`Infringement Experts: 7 hours per asserted patent plus 3 hours per each additional
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`Manufacturer Defendant beyond the first.
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` Validity Experts: 5 hours per asserted patent.
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`Case 6:14-cv-00982-KNM Document 82 Filed 06/19/15 Page 2 of 3 PageID #: 534
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` Damages and Other Experts: 5 hours per asserted patent plus 3 hours per each
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`additional Manufacturer Defendant beyond the first.
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`Therefore, AT&T respectfully requests that the Court adopt its proposed Discovery
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`Order.
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`Dated: June 19, 2015
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`Respectfully submitted,
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`/s/ Christopher W. Kennerly
`Christopher W. Kennerly
`TX Bar No. 00795077
`chriskennerly@paulhastings.com
`Jeffrey G. Randall
`CA Bar No. 130811
`jeffrandall@paulhastings.com
`Paul Hastings LLP
`1117 S. California Ave.
`Palo Alto, CA 94304-1106
`Telephone: (650) 320-1800
`Facsimile: (650) 320-1900
`
`Jeffrey D. Comeau
`CA Bar No. 259679
`jeffreycomeau@paulhastings.com
`PAUL HASTINGS LLP
`4747 Executive Drive
`Twelfth Floor
`San Diego, CA 92121-3114
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`
`Trey Yarbrough
`TX Bar No. 22133500
`trey@yw-lawfirm.com
`YARBROUGH WILCOX, PLLC
`100 E. Ferguson St., Suite 1015
`Tyler, Texas 75702
`Telephone (903) 595-3111
`Facsimile (903) 595-019
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`ATTORNEYS FOR AT&T MOBILITY
`LLC
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`2
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`CERTIFICATE OF CONFERENCE
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`Pursuant to Local Rule CV-7(h), I certify that between June 12 and 19, counsel for
`AT&T met and conferred with the parties. Counsel for Plaintiff indicated that they oppose the
`relief requested.
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`/s/ Christopher W. Kennerly
`Christopher W. Kennerly
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`Case 6:14-cv-00982-KNM Document 82 Filed 06/19/15 Page 3 of 3 PageID #: 535
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing document was filed
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`electronically in compliance with Local Rule CV-5 on this 19th day of June, 2015. As of this
`date all counsel of record have consented to electronic service and are being served with a copy
`of this document through the Court’s CM/ECF system under Local Rule CV-5(a)(3)(A).
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`/s/ Christopher W. Kennerly
`Christopher W. Kennerly
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