I/P Engine, Inc. v. AOL, Inc. et al
Filing
438
Declaration re 433 Opposition, 432 Opposition, 434 Opposition, of Margaret P. Kammerud in Support of Defendants' Opposition to Plaintiff's Motions in Limine by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M)(Noona, Stephen)
EXHIBIT I
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION
__________________________________________
)
)
)
Plaintiff,
)
v.
)
)
AOL, INC. et al.,
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Defendants.
)
__________________________________________)
I/P ENGINE, INC.,
Civ. Action No. 2:11-cv-512
PLAINTIFF I/P ENGINE’S INITIAL PRETRIAL DISCLOSURE
Plaintiff I/P Engine, Inc. (“I/P Engine”) submits the following initial pretrial disclosures
pursuant the Federal Rules of Civil Procedure, the Local Rules of this Court, and this Court’s
16(b) Scheduling Order.
I.
WITNESSES
I/P Engine identifies the following individuals as those it expects to present and those it
may call at trial during its case-in-chief. I/P Engine reserves the right to amend its list prior to
the Final Pretrial Conference in light of the ongoing depositions scheduled in this case.
A.
I/P Engine expects to call the following witnesses:
1. Andrew K. Lang
2. Dr. Ophir Frieder
3. Dr. Stephen L. Becker
4. Dr. Jaime Carbonell
B.
I/P Engine may call the following witnesses:
1. Gary Holt
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2. Donald M. Kosak
3. Alexander Berger
4. Andrew Perlman
C.
I/P Engine expects to or may call the following witnesses at trial by
deposition:
1. Derek Leslie-Cook*
2. Gary Holt*
3. Bartholomew Furrow*
4. Jonathan Alferness*
5. Robert Hickernell
6. Sanjay Datta*
7. Jim Maccoun*
8. Nicholas Fox*
9. Jon Diorio*
10. Mark Blais
11. Stephen Kurtz
12. James Christopherson
13. Celia Denery
14. Ruben Ortega*
15. Gary Culliss
I/P Engine reserves the right to call by deposition any witness listed as one that it expect
to call or may call.1 I/P Engine reserves its right to call any witness in rebuttal.
* designates a current Google employee. I/P Engine reserves the right to call this witness live.
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II.
DEPOSITION DESIGNATIONS
I/P Engine’s initial designation of those witnesses whose testimony it expects to present
by deposition or may offer into evidence at trial is attached hereto as Exhibit A. I/P Engine
reserves the right to amend its designations prior to the Final Pretrial Conference in light of the
ongoing depositions scheduled in this case, and consistent with the agreements of the parties and
the Final Pretrial Order.2
III.
EXHIBITS
I/P Engine’s initial documents that it expects to offer into evidence at trial as part of its
case-in-chief, is attached hereto as Exhibit B. This list of exhibits does not include exhibits used
on cross-examination, rebuttal, demonstrative exhibits, and discovery responses. I/P Engine
1
I/P Engine’s listing of certain witnesses is not an admission that any such witness’ testimony is
relevant to the issues of the present litigation. I/P Engine reserves its right to object for any
reason to the testimony of those witnesses.
2
I/P Engine specifically reserves the right to add its designations for the deposition of Jon
Diorio, who was deposed on September 18, 2012, the deposition of Ruben Ortega, who will be
deposed on September 25, 2012, and the deposition of Gary Culliss, who will be deposed on
September 27, 2012.
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reserves its right to use any exhibit identified by any other party. I/P Engine reserves the right to
amend its case-in-chief list prior to the Final Pretrial Conference in light of the ongoing
depositions scheduled in this case.
Dated: September 19, 2012
By:
/s/ Charles J. Monterio, Jr.
Jeffrey K. Sherwood
Frank C. Cimino, Jr.
Kenneth W. Brothers
Dawn Rudenko Albert
Charles J. Monterio, Jr.
DICKSTEIN SHAPIRO LLP
1825 Eye Street, NW
Washington, DC 20006
Telephone: (202) 420-2200
Facsimile: (202) 420-2201
Donald C. Schultz
W. Ryan Snow
CRENSHAW, WARE & MARTIN PLC
150 West Main Street
Norfolk, VA 23510
Telephone: (757) 623-3000
Facsimile: (757) 623-5735
Counsel for Plaintiff I/P Engine, Inc.
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CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of September, 2012, the foregoing PLAINTIFF I/P
ENGINE’S INITIAL PRETRIAL DISCLOSURE, was served via email, on the following:
Stephen Edward Noona
Kaufman & Canoles, P.C.
150 W Main St
Suite 2100
Norfolk, VA 23510
senoona@kaufcan.com
David Bilsker
David Perlson
Quinn Emanuel Urquhart & Sullivan LLP
50 California Street, 22nd Floor
San Francisco, CA 94111
davidbilsker@quinnemanuel.com
davidperlson@quinnemanuel.com
Robert L. Burns
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
robert.burns@finnegan.com
Cortney S. Alexander
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, GA 94111
cortney.alexander@finnegan.com
/s/ Armands Chagnon
Senior Paralegal
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