Lam Research Corporation v. Schunk Semiconductor et al

Filing 319

ORDER Granting Request for Extension of Time to 5/16/14 to provide letters to the Court. Signed by Judge Joseph C. Spero on 5/8/14. (klhS, COURT STAFF) (Filed on 5/8/2014)

SHAUB & WILLIAMS LLP
DAVID R. SHAUB
LESLIE G. WILLIAMS
LISBETH BOSSHART MERRILL *

ATTORNEYS AT LAW

LOS ANGELES, CA 90025

*ALSO ADMITTED IN NEW YORK

TELEPHONE: [phone]

*PATENT ATTORNEY ADMITTED IN COLORADO

FACSIMILE: [phone]

DAVID ROSENBAUM**

E-MAIL: [e-mail]

CASSANDRA M. TAM
KATYA MEZEK
REBECCA HAAKE *

NETWORK ATTORNEYS
ALICE A. SUN
ROBERT C. MATZ
JENNIFER M. MCCALLUM*

**PATENT ATTORNEY ADMITTED IN ILLINIOS

12121 WILSHIRE BOULEVARD, SUITE 205

The Hon. Joseph C. Spero
United States District Court for the Northern District of California
450 Golden Gate Avenue, Courtroom G, 15th Floor
San Francisco, CA 9410

May 6, 2014

Re:

Discovery Meet and Confer Requested by Plaintiff’s Counsel
3:03-cv-1335 EMC (JCS)
Dear Judge Spero,
On March 17, 2014, counsel for Defendant Xycarb Ceramics, Inc. (“Xycarb”), Lisbeth
Merrill sent a letter to the above counsel for Plaintiff Lam Research Corporation (“Lam”)
complaining of Lam’s deficiencies in discovery responses. On April 2, 1014, Lam responded to the
letter in an extremely high level, non-substantive manner. On April 15, 2014, Mrs. Merrill raised
Xycarb’s issues with Lam’s discovery and a potential motion to compel to Judge Chen at the status
conference, and Judge Chen informed the parties that the matter was referred to your Honor for
discovery disputes. On April 16, 2014, Xycarb’s counsel sent an additional letter addressing again
Lam’s discovery deficiencies and requesting an in person meet and confer with Stuart Clark for
April 28, 2014, at or about the time both parties and their counsel would be in San Jose for the Court
ordered mediation. On April 30, 2014, the parties’ above counsel met and conferred in person in
Northern California where Mr. Clark works and resides. During that meet and confer, the parties
discussed amending existing responses to comply with Your Honor’s standing order regarding
discovery responses. Further, although Lam seemed to substantively disagree with most of Xycarb’s
points, Lam’s counsel wanted time to review the responses and send a follow-up response.
This week, Lam’s counsel requested an extension of 30 days for the meet and confer process
deadlines. Xycarb’s counsel stated that it could grant until May 16, 2014 for Lam to supplement its
responses to comply with Your Honor’s standing order and to indicate substantively what responses
Lam is willing to supplement.
As a result, Xycarb respectfully requests an extension until May 16, 2014 to provide its
letters to the Court pursuant to the standing order in hopes that some of the issues can be resolved
without Court intervention. If appropriate, based upon Lam’s response, Xycarb may request of the
Court additional time pursuant to Lam’s request.

ASSOCIATED WITH ROSENBAUM & SILVERT AND JENNIFER MCCALLUM
PATENT ATTORNEYS – CHICAGO, IL & DENVER, CO

Respectfully submitted,
SHAUB &WILLIAMS LLP
By: /s/ Lisbeth Bosshart Merrill
Lisbeth Bosshart Merrill

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Dated: 5/8/14

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Attorneys for Xycarb Ceramics, Inc.

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ASSOCIATED WITH ROSENBAUM & SILVERT AND JENNIFER MCCALLUM
PATENT ATTORNEYS – CHICAGO, IL & DENVER, CO