`Case 6:20-cv-01213-ADA Document 70-7 Filed 03/04/22 Page 1 of 2
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`EXHIBIT F
`EXHIBIT F
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`Case 6:20-cv-01213-ADA Document 70-7 Filed 03/04/22 Page 2 of 2
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`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Counsel:
`
`Stewart, Doug <doug.stewart@bracewell.com>
`Thursday, January 20, 2022 6:39 PM
`oceansemi-dlf
`Bracewell-IP; Timothy Devlin; DLF-Lit Paras; Henrik Parker
`Ocean Semiconductor--reissued subpoenas
`
`We have been informed by our client, Kioxia America Inc., that the eight subpoenas which were the subject of our
`recent motions to quash have been reissued and served. While we appreciate that you have corrected the location of
`production/deposition to comply with the rules, it appears that the newly-issued subpoenas are of substantially the
`same scope as the originals. As laid out in our previously-filed motions, the scope of the subpoenas are grossly
`overbroad and responding to the subpoenas in their current form would subject Kioxia America to undue
`burden. Because we previously raised this problem in our motions, but you took no corrective action to address it prior
`to reissuing the subpoenas, we presume that you intend to stand by your overreaching demands. If that is the case, we
`will refile our motions to quash. Therefore, please confirm if that is your intent. If it is not, please propose how you
`intend to narrow the requests. We are willing to discuss your proposal on a meet and confer next week.
`
`Thanks,
`
`Doug
`
`______
`DOUG STEWART
`Partner
`Doug.Stewart@bracewell.com
`T: +1.206.204.6271 | F: +1.800.404.3970
`
`BRACEWELL LLP
`701 Fifth Ave Suite 6200 | Seattle, WA | 98104-7018
`bracewell.com | attorney profile | download v-card
`
`CONFIDENTIALITY STATEMENT
`This message is sent by a law firm and may contain information that is privileged or confidential. If you received
`this transmission in error, please notify the sender by reply e-mail and delete the message and any
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`
`1
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