STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY TO OCCUR AFTER SEPTEMBER 5, 2014

SAMUEL CONTI, District Judge.

Defendants Hitachi, Ltd., Hitachi Displays, Ltd., Hitachi Asia, Ltd., Hitachi America, Ltd., and Hitachi Electronic Devices (USA), Inc. (collectively, the "Hitachi Defendants") and the undersigned Defendants (collectively, "Defendants") and plaintiffs Electrograph Systems, Inc. and Electrograph Technologies Corp. (collectively, "Electrograph") have conferred by and through their counsel and, subject to the Court's approval, HEREBY STIPULATE AS FOLLOWS:

WHEREAS, September 5, 2014 is the deadline to complete fact discovery in the Electrograph action;

WHEREAS, on July 23, 2014, Defendants informed Electrograph of their intent to subpoena for deposition five former employees of Electrograph—Alex Ivani, Rabih Chikhani, Lou Azzam, Kathy Koziol, and Sam Taylor—and requested deposition dates for those witnesses;

WHEREAS, Electrograph informed Defendants that its counsel had limited availability to attend the depositions of former Electrograph employee witnesses during the month of August and therefore requested that Defendants schedule those depositions for September;

WHEREAS, Electrograph and Defendants have conferred and agreed that Defendants may depose former Electrograph employees after September 5, 2014;

WHEREAS, Electrograph and Defendants have conferred and agreed to schedule the deposition of Kathy Koziol for September 16, 2014, the deposition of Sam Taylor for September 18, 2014, the deposition of Alex Ivani for October 16, 2014, and the depositions of Robbie Chikhani and Lou Azzam for dates, still to be determined, after September 5, 2014 but no later than October 31, 2014;

WHEREAS, Electrograph and Defendants agree to negotiate and cooperate in good faith with respect to the scheduling of any depositions that may occur after September 5, 2014, subject to the Court's Discovery Protocol (Dkt. No. 1128);

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED between counsel as follows:

1. Defendants may subpoena, notice, and take additional depositions of former Electrograph employees Alex Ivani, Rabih Chikhani, Lou Azzam, Kathy Koziol, and Sam Taylor after September 5, 2014 but no later than October 31, 2014, subject to the Court's Discovery Protocol (Dkt. No. 1128); and

2. To the extent motions to compel may be required for item 1 above, Defendants may file those motions within ten days after the depositions in question.

PURSUANT TO STIPULATION, IT IS SO ORDERED.