Mirror Worlds, LLC v. Apple, Inc.
REBUTTAL TRIAL Witness List by Apple, Inc.. (Randall, Jeffrey)
Mirror Worlds, LLC v. Apple, Inc.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. JURY TRIAL DEMANDED Civil Action No. 6:08-cv-88 LED
DEFENDANT AND COUNTERCLAIM PLAINTIFF APPLE INC.'S REBUTTAL TRIAL WITNESS LIST
Pursuant to the Court's Docket Control Order entered in this matter, Defendant and Counterclaim Plaintiff Apple Inc. ("Apple") hereby respectfully submits its Rebuttal Trial Witness List. At this time, Apple identifies the following witnesses for Trial that will appear either live and/or by deposition as rebuttal witnesses: Witness Will Call May Call By deposition videotape or transcript X X Live (if available)
Don Lindsay Jacob Jacoby
Apple reserves the right to call in rebuttal any witness listed on Apple's Trial Witness List or Mirror Worlds LLC or Mirror Worlds Technologies, Inc's (collectively, "Mirror Worlds") Witness List and/or Rebuttal Witness List, and any witness listed on Mirror Worlds or Apple's initial disclosures, amended or supplemented, either live or by way o f a deposition. Apple reserves the right to further supplement their identification of rebuttal trial witnesses with additional fact and expert witnesses as may be disclosed in subsequent discovery. As of the date of this filing, discovery, including depositions, is still ongoing. In addition, Apple reserves the right to call any fact and/or expert witness(es) to rebut evidence offered by Mirror Worlds in its case-in-chief. Apple reserves the right to withdraw any rebuttal fact or expert witness(es) before or during trial. For Apple's "may call" wit nesses, Apple does not currently have information on each of the witnesses' availabilit y for trial or the burden that it would place on them to appear at trial. In accordance with the Court's Docket Control Order, Apple may also introduce testimony via designated portions of depositions, including portions of depositions of Mirror Worlds' Fed. R. Civ. P. 30(b)(6) designee(s), portions of depositions of witnesses affiliated or associated with Mirror Worlds, and portions of depositions of unavailable witnesses. Apple shall provide its designations in accordance with the timing set forth in the Court's Docket Control Order. /// /// /// ///
Dated: June 21, 2010
Respect fully submitted, /s/ Jeffrey G. Randall Jeffrey G. Randall Lead Attorney PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 1117 S. California Avenue Palo Alto, California 94304-1106 Telephone: (650) 320-1850 Facsimile: (650) 320-1950 jeffrandall@paulhast ings.co m Allan M. Soobert PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 875 15th Street, N.W. Washington, DC 20005 Telephone: (202) 551-1822 Facsimile: (202) 551-0222 allansoobert@paulhast ings.co m S. Christian Platt PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 4747 Executive Dr., 12th Floor San Diego, CA 92121 Telephone: (858) 458-3034 Facsimile: (858) 458-3005 christ ianplatt@paulhast ings.co m Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: (903) 757-8449 Facsimile: (903) 758-7397 email@example.com Counsel for Defendant and Counterclaim Plaintiff, APPLE INC.
CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was filed electronically in compliance with Local Rule CV-5 on this 21st day of June, 2010. 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).
/s/ Jeffrey G. Randall Jeffrey G. Randall
LEGAL_US_E # 88617099