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)

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EXHIBIT I UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION __________________________________________ ) ) ) Plaintiff, ) v. ) ) AOL, INC. et al., ) ) 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 DSMDB-3098955 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. 2 DSMDB-3098955 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. 3 DSMDB-3098955 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. 4 DSMDB-3098955 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 5 DSMDB-3098955

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