Free Notice to Take Deposition - District Court of Delaware - Delaware

Case 1:04-cv-00904-KAJ

Document 96

Filed 07/19/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE W. C. HERAEUS GMBH & Co. KG (a German corporation), and HERAEUS INCORPORATED (a Delaware corporation), Plaintiffs. v. MARJORIE JOY LYNN as Personal Representative for the ESTATE OF DAVID MARK LYNN and as Trustee of the MARK AND MARJORIE LYNN REVOCABLE TRUST, LYNN PLASMA, INC. (an Idaho corporation), and NXEDGE, INC. (a Delaware corporation) Defendants. C.A. No. 04-904 (KAJ)

PLAINTIFFS' NOTICE OF TAKING VIDEOTAPED DEPOSITIONS TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Plaintiffs W.C. Heraeus GmbH and Heraeus Incorporated, through undersigned counsel, will take the videotaped depositions of the following persons at the places and times listed below (or at such other places and times as may be mutually agreed upon). The depositions will be taken by stenographic, audio, video, and/or real-time computer means (e.g. Live Note) before an officer authorized to administer oaths. The depositions will be taken for the purpose of discovery, for use at trial in this matter, and for any other purpose permitted under the Federal Rules of Civil Procedure.

Case 1:04-cv-00904-KAJ

Document 96

Filed 07/19/2005

Page 2 of 3

ALSO, PLEASE TAKE NOTICE that the depositions will proceed in accordance with the provisions of Rule 30 of the Federal Rules of Civil Procedure, and will continue from day to day, excluding weekends and holidays, until completed. You are invited to attend. Deponent Mel Clarkson Chris Potter Tony Mariani Brian Stuart Brian Guthmiller Date August 11, 2005 August 11, 2005 August 12, 2005 August 12, 2005 August 15, 2005 Time 9:00 a.m. 1:00 p.m. 9:00 a.m. 1:00 p.m. 9:00 a.m. Location for all Depositions The offices of NxEdge located at 7500 W. Mossy Cup St. Boise, Idaho 83709

MORRIS, NICHOLS, ARSHT & TUNNELL /s/ Leslie A. Polizoti Karen Jacobs Louden (#2881) Leslie A. Polizoti (#4299) 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 (302) 658-9200 Attorneys for Plaintiffs W.C. Heraeus GmbH and Heraeus Incorporated

OF COUNSEL: Fay Morisseau Mark Itri Dennis A. Duchene 18191 Von Karman Ave., Suite 400 Irvine, CA 92612-7107 (949) 851-0633 July 19, 2005
474857

Case 1:04-cv-00904-KAJ

Document 96

Filed 07/19/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on July 19, 2005, I electronically filed the foregoing document with the Clerk of Court using CM/ECF, which will send notification of such filing to Kevin M. Baird and Karen Jacobs Louden. I also certify that on July 19, 2005, I caused to be served true and correct copies of the foregoing document on the following in the manner indicated below:

BY HAND Kevin M. Baird CONNOLLY BOVE LODGE & HUTZ LLP The Nemours Building 1007 N. Orange Street P.O. Box 2207 Wilmington, DE 19899 BY FEDERAL EXPRESS B. Newal Squyres HOLLAND & HART LLP U.S. Bank Plaza 101 S. Capitol Blvd., Suite 1400 Boise, ID 83702 Lawrence D. Graham BLACK LOWE & GRAHAM, PLLC 701 Fifth Ave., Suite 4800 Seattle, WA 98104

/s/ Leslie A. Polizoti MORRIS, NICHOLS, ARSHT AND TUNNELL (302) 658-9200 [email protected]