Lulu Enterprises, Inc. v. N-F Newsite, LLC et al

Filing 32

NOTICE by Lulu Enterprises, Inc., N-F Newsite, LLC Joint Plan for Expedited Discovery (Silver, Hayden)

Lulu Enterprises, Inc. v. N-F Newsite, LLC et al

Doc. 32

Case 5:07-cv-00347-D

Document 32

Filed 09/18/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION NO. 5:07-cv-00347-D LULU ENTERPRISES, INC., Plaintiff, vs. N-F NEWSITE, LLC, and HULU TECH, INC., Defendants. Plaintiff Lulu Enterprises, Inc. ("Lulu") and Defendant Hulu, LLC formerly known as NF NewSite, LLC ("Hulu") hereby submit their joint plan for expedited discovery, as required by this Court's September 14, 2007 Order. 1. The parties have already exchanged expedited discovery requests and Notices of JOINT PLAN FOR EXPEDITED DISCOVERY

Deposition. The requests and notices are attached to this Joint Plan for Expedited Discovery as Exhibits A (Plaintiff's Requests) and B (Defendant's Requests). 2. The parties anticipate that some of the responsive documents are confidential and

proprietary. Accordingly, in the very near future, the parties will submit a proposed Consent Protective Order to the Court for its consideration. 3. Unless otherwise agreed, the parties shall exchange responses to the expedited

discovery requests, including production of the responsive documents, by 6:00 pm on Tuesday, September 24, 2007.

US2000 10316901.2

Dockets.Justia.com

Case 5:07-cv-00347-D

Document 32

Filed 09/18/2007

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4.

Unless otherwise agreed, Plaintiff will take the deposition of Hulu on Thursday,

September 27, 2007 at 1:00 p.m. in Los Angeles, California at 2121 Avenue of the Stars, Suite 700. The deposition shall last no longer than four hours. 5. Unless otherwise agreed, Defendant will take the deposition of Lulu on

Wednesday, October 3, 2007 at 10:00 a.m. in Cary, North Carolina at the offices of Ellis & Winters. The deposition shall last no longer than four hours. Respectfully submitted, this the 18th day of September, 2007. /s/ Leslie C. O'Toole Leslie C. O'Toole NC State Bar No. 13640 [e-mail] Thomas H. Segars NC State Bar No. 29433 [e-mail] ELLlS & WINTERS LLP P.O. Box 33550 Raleigh, NC 27636 [phone] [phone] facsimile Counsel for Plaintiff Lulu Enterprises, Inc. William H. Brewster GA State Bar No. 080422 [e-mail] Sara Maurer GA State Bar No. 159056 [e-mail] KILPATRICK STOCKTON LLP 1100 Peachtree Street Suite 2800 Atlanta, GA 30309 [phone] [phone] facsimile Counsel for Defendant Hulu, LLC /s/ Hayden J. Silver, III Hayden J. Silver, III NC State Bar No. 10037 [e-mail] Betsy Cooke NC State Bar No. 25353 [e-mail] KILPATRICK STOCKTON LLP 3737 Glenwood Avenue, Suite 400 Raleigh, NC 27612 [phone] [phone] facsimile

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