Fenerjian v. Nong Shim Company, Ltd et al

Filing 204

Order by Magistrate Judge Donna M. Ryu GRANTING AS MODIFIED 203 Stipulation.(dmrlc2, COURT STAFF) (Filed on 9/10/2015)

Case3:13-cv-04115-WHO Document203 Filed09/09/15 Page1 of 6

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[SUBMITTING COUNSEL SHOWN ON
SIGNATURE PAGES]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION

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IN RE KOREAN RAMEN ANTITRUST
LITIGATION

Case No. 3:13-cv-04115-WHO-DMR
STIPULATION AND [PROPOSED]
ORDER REGARDING CUSTODIAN
AND SEARCH TERM MEET AND
CONFER

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THIS DOCUMENT RELATES TO:

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All Actions

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STIPULATION AND [PROPOSED] ORDER -- Case No. 3:13-cv-04115-WHO-DMR
010-8131-5387/2/AMERICAS

Case3:13-cv-04115-WHO Document203 Filed09/09/15 Page2 of 6

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WHEREAS, on September 2, 2015 the Parties submitted a stipulation and proposed order

2 regarding the deadline to complete meeting and conferring regarding search terms and custodians to be
3 searched (Doc. No. 201) seeking to move the deadline to file a joint letter with the Court regarding any
4 unresolved issues by September 9, 2015;
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WHEREAS, on September 2, 2015 the Court approved the parties’ stipulation, entering an

6 order setting September 9, 2015 as the date by which the Parties were to submit a joint letter to the
7 Court addressing any unresolved issues regarding search terms and custodians to be searched;
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WHEREAS, the Parties are continuing to meet and confer regarding the search terms and

9 proposed custodians;
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WHEREAS, the Parties believe that further meet and confer efforts will be useful in eliminating

11 (or at least narrowing) any disputes on these issues;
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NOW, THEREFORE, THE PARTIES, BY AND THROUGH THEIR RESPECTIVE

13 UNDERSIGNED COUNSEL, HEREBY STIPULATE TO AN ORDER OF THE COURT AS
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1.

The Parties agree to continue to meet and confer regarding search terms and custodians

to be searched through September 16, 2015.
2.

As meet and confer discussions have progressed, the Parties are also cognizant of factors

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that bear on the meet and confer process. Rather than burdening the Court with a stipulation and

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a proposed order on a weekly basis, the Parties agree to continue with their good faith efforts to

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finalize search terms and custodians to be searched and will promptly submit a joint discovery

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letter in accordance with this Court’s Standing Order if an impasse is reached.

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23 Signatures of Submitting Parties on the Following Page
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-1STIPULATION AND [PROPOSED] ORDER -- Case No. 3:13-cv-04115-WHO-DMR

Case3:13-cv-04115-WHO Document203 Filed09/09/15 Page3 of 6

1 Dated: September 9, 2015

HAUSFELD LLP

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By:

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Christopher L. Lebsock
600 Montgomery Street
Suite 3200
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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/s/ Christopher L. Lebsock

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GLANCY PRONGAY AND MURRAY LLP
Lee Albert
122 East 42nd Street Suite 2920
New York, NY 10168
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Interim Lead Counsel for the Direct Purchaser Plaintiffs

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14 Dated: September 9, 2015

IZARD NOBEL LLP

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By:

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Jeffrey S. Nobel
29 South Main Street, Suite 305
West Hartford, CT 06107
Telephone: [phone]
E-mail: [e-mail]

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/s/ Jeffrey S. Nobel

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Interim Lead Counsel for the Indirect Purchaser
Plaintiffs

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SQUIRE PATTON BOGGS (US) LLP

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By:

/s/ Anne Choi Goodwin

Anne Choi Goodwin
Attorneys for Defendants
Nongshim Co. Ltd. and Nongshim America, Inc.

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-2STIPULATION AND [PROPOSED] ORDER -- Case No. 3:13-cv-04115-WHO-DMR

Case3:13-cv-04115-WHO Document203 Filed09/09/15 Page4 of 6

1 Dated: September 9, 2015

GIBSON, DUNN & CRUTCHER LLP

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By:

/s/ Minae Yu

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Minae Yu
Attorneys for Defendants
Ottogi Co. Ltd. and Ottogi America, Inc.

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-3STIPULATION AND [PROPOSED] ORDER -- Case No. 3:13-cv-04115-WHO-DMR

Case3:13-cv-04115-WHO Document203 Filed09/09/15 Page5 of 6

ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

UNIT
ED

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The parties shall file a joint discovery letter
by September 30, 2015.

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Dated: September __, 2015

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-1STIPULATION AND [PROPOSED] ORDER -- Case No. 3:13-cv-04115-WHO-DMR

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