STC.UNM v. Intel Corporation
MOTION for Order RULE 56(d) MOTION TO ADD TWO EXHIBITS by STC. UNM. (Attachments: # 1 Exhibit 9, # 2 Exhibit 10, # 3 Exhibit 11)(Pedersen, Steven)
UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
Civil No. 10-CV-01077-RB-WDS
STC.UNM'S RULE 56(d) MOTION TO ADD TWO EXHIBITS
Pursuant to Fed. R. Civ. P 56(d), STC.UNM requests that the Court accept the following
evidence attached hereto:
1. The “Fictitious Business Name Statement” filed by Sandia Corporation with
the Alameda County Clerk-Recorder which establishes that Sandia Corporation
has been using Sandia National Laboratories as a DBA, fictitious business name,
since 1985. Ex 9. This supports STC.UNM’s position that Sandia National
Laboratories is a DBA of Sandia Corporation.
2. Deposition testimony Intel obtained from Sandia Corporation which establishes
that Sandia Corporation obtained ownership of the ‘321 patent from the
Department of Energy pursuant to 42 U.S.C. § 5908 of the Atomic Energy Act.
Ex 10. This addresses Intel’s new Atomic Energy Act argument raised in Doc
204 at page 2.
The requirements of Rule 56(d) have been met as set forth in the attached affidavit (Ex
11) since STC.UNM recently learned of the Fictitious Business Name Statement and the
deposition testimony addresses Intel’s newest argument that Sandia Corporation failed to obtain
ownership of the ‘321 patent from the Department of Energy as a result of the automatic vesting
provisions of the Atomic Energy Act.
Intel has informed STC.UNM that it opposes this motion.
Dated: April 25, 2012
Deron B. Knoner
KELEHER & MCLEOD, P.A
201 Third Street NW, 12th Floor
PO Box AA
Albuquerque, New Mexico 87103
/s/ Steven R. Pedersen
Rolf O. Stadheim
Joseph A. Grear
George C. Summerfield
Keith A. Vogt
Steven R. Pedersen
STADHEIM & GREAR, LTD.
400 N. Michigan Avenue, Suite 2200
Chicago, Illinois 60611
Raúl A. Carrillo Jr.
CARILLO LAW FIRM, P.C.
937 East Lohman
Las Cruces, New Mexico 88001
Attorneys for Plaintiff STC.UNM
Certificate of Service: I hereby certify that on April 25, 2012, I caused the foregoing to be
electronically filed with the Clerk of the Court using the CM/ECF system which will send
notification of such filing via electronic mail to all counsel of record.
/s/ Steven R. Pedersen
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