Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al

Filing 41

Letter from Plaintiff, Stanford University re [Proposed] Order re Interviewing Witnesses Pursuant to Telephone Conference held on May 23, 2006. (Rhyu, Michelle) (Filed on 6/1/2006)

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Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al Doc. 41 Case 3:05-cv-04158-MHP Document 41 Filed 06/01/2006 ATTORNEYS AT LAW Page 1 of 1 Broomfield, CO 720 566-4000 Reston, VA 703 456-8000 San Diego, CA 858 550-6000 San Francisco, CA 415 693-2000 Washington, DC 202 842-7800 May 31, 2006 May 22, 2006 VIA E-FILE Honorable Marilyn Hall Patel United States District Court, N. D. CA 450 Golden Gate Ave., Courtroom 15 San Francisco, CA 94102 Five Palo Alto Square 3000 El Camino Real Palo Alto, CA 94306-2155 Main 650 843-5000 Fax 650 857-0663 www.cooley.com MICHELLE S. RHYU, Ph.D. (650) 843-5505 rhyums@cooley.com Re: Stanford University v. Roche Molecular Systems, et al. (Case No.C 05-04158 MHP) Your Honor: Plaintiff, Stanford University, respectfully submits the attached Proposed Order pursuant to the telephonic conference held on May 23, 2006. Following the Court's instruction to obtain approval from defendants as to form, plaintiffs provided a draft of the Proposed Order to defendant's counsel on May 24, 2006. Plaintiff incorporated revisions requested by defendants regarding contacting individuals represented by counsel. However, defendants have insisted on inserting limitations in the Proposed Order relating to time limits and methods of recording the interviews. As these issues were never discussed in the May 23, 2006 conference, plaintiff opposed inserting such restrictions into the Court's Order. Although defendant's objections go to the substance rather than the form of the order, they refuse to approve the form of the Proposed Order without these limitations. Accordingly, plaintiff cannot represent that defendants have approved this Proposed Order. Review of the transcript of the May 23 teleconference will confirm that this Proposed Order is wholly consistent with the Court's instructions. Respectfully submitted, /s/ Michelle S. Rhyu cc: Jeremy Burns Brian Cannon 728506 v2/PA Dockets.Justia.com

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