Navcom Techonology, Inc et al v. OKI Semiconductor America, Inc et al

Filing 86

STIPULATION AND ORDER Re: Deposition at the United States Embassy, Tokyo Japan. Signed by Magistrate Judge Howard R. Lloyd on July 31, 2013. (hrllc1, COURT STAFF) (Filed on 7/31/2013)

*E-FILED: July 31, 2013*
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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Case No. 5:12-cv-04175 EJD

NAVCOM TECHNOLOGY, INC.; AND
DEERE & COMPANY,

[PROPOSED] ORDER REGARDING
DEPOSITION OF DEFENDANT OKI
ELECTRIC INDUSTRY CO., LTD.
PURSUANT TO FED. R. CIV. P.
30(B)(6) AT THE UNITED STATES
EMBASSY, TOKYO JAPAN

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Plaintiffs,
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vs.
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OKI ELECTRIC INDUSTRY CO., LTD.;
and DOES 1 through 10, inclusive,

Judge:
Hon. Edward J. Davila
Date of Filing:
06/22/2012
July 31, 2013

Defendants.

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
S AN FRANCISCO

DB2/ 24257645.1

[PROPOSED] ORDER RE
DEPOSITION OF OKI
5:12-CV-04175 EJD

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TO ANY CONSUL OR VICE-CONSUL OF THE UNITED STATES ASSIGNED
TO TOKYO, JAPAN:
WHEREAS, the above-captioned civil lawsuit has been pending before this Court since
July 2012;
WHEREAS, the Plaintiffs NavCom Technology, Inc. and Deere & Company allege

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breach of contract by Defendant Oki Electric Industry Co., Ltd.;

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WHEREAS, discovery began in November 2012;

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WHEREAS, Plaintiffs have reserved a deposition room at the United States Embassy in

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Tokyo, Japan for taking depositions from September 9-10, 2013;
On stipulation of Parties, and pursuant to Article 17 of the United States-Japan Consular
Convention of 1963, 15 U.S.T. 768,
IT IS ORDERED that the depositions of the following witnesses, who will appear
voluntarily, be taken at the United States Embassy in Tokyo, Japan:

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Name:

Yoko Goto

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Employer:

Oki Electric Industry Co., Ltd.

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Address:

1-7-12 Toranomon Minato-ku Tokyo 105-8460, Japan

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Deposition of the above individual will commence on or about September 9, 2013 at 8:30 a.m.

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(local time) and conclude on or about September 10, 2013, at 5:00 p.m. (local time).

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Counsel for Plaintiffs who will participate in said depositions include one or more of the
following: Brett M. Schuman, Ryan L. Scher and Rachel M. Walsh.
Counsel for Defendant who will participate in said depositions include one or more of the
following: Marc R. Labgold, Patrick J. Hoeffner, Takaaki Nagashima and Yuichiro Yasutomo.
In addition to counsel for Plaintiffs, Navcom and/or Deere & Co. corporate
representatives Patricia Harris will attend.
In addition to the deponents and counsel for Defendants, Oki corporate representatives
Mr. Isao Goto and Ms. Mikiko Higashino will also attend.

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
S AN FRANCISCO

DB2/ 24257645.1

[PROPOSED] ORDER RE
DEPOSITION OF OKI
5:12-CV-04175 EJD

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The proceedings will be reported by Karen Claire Young, Cynthia Renee Ott, Robert

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Vance Short, Leslie Anne Todd, Susan Dena Wasilewski, Melanie Louise Giamarco, Deborah

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Ruth Marshall, Lisa A. Knight, Tracy LoCastro, James Vernon Beasley, Jodi Beth Harmon and/or

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Keith Shreckengast. The proceedings will be recorded on video by Paul B. Diserio, Paul Michael

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Goldberg and/or Daniel Dean of Legal Video Asia. Grace Liu, Toyu Yazaki and/or William Lise

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will act as interpreters.

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The transcripts of the deposition will be prepared and distributed among the interested
parties by the court reporter without further involvement by the United States Embassy

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The parties respectfully request that the Court provide five certified copies of the Order

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pursuant to these stipulations, to be mailed by Parties’ counsel to the United States Embassy in

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Tokyo, Japan.

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IT IS SO ORDERED.

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Dated: July 31, 2013
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By
HONORABLE HOWARD R. LLOYD

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
S AN FRANCISCO

DB2/ 24257645.1

[PROPOSED] ORDER RE
DEPOSITION OF OKI
5:12-CV-04175 EJD