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Case 1:17-cv-00770-JDW-MPT Document 170 Filed 03/10/23 Page 1 of 2 PageID #: 15436
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR DISTRICT OF DELAWARE
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`WIRTGEN AMERICA, INC.,
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`Plaintiff/Counterclaim-Defendant,
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`
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`v.
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`CATERPILLAR INC.,
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`Defendant/Counterclaim-Plaintiff.
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`)
`)
`)
`)
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`)
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`C.A. No. 17-770-JDW-MPT
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`JURY TRIAL DEMANDED
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`DEFENDANT’S NOTICE OF 30(b)(1) DEPOSITION OF BRAD MCKINNEY
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`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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`PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules of Civil Procedure
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`and the applicable Local Civil Rules of the United States District Court for the District of
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`Delaware, Defendant and Counterclaim-Plaintiff Caterpillar Inc. (“Caterpillar”), by and through
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`their attorneys, will take the deposition upon oral examination of Brad McKinney on March 22,
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`2023 at 9:00 a.m., the date and time mutually agreed upon by the parties, at a mutually agreed
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`location at or near Patterson Intellectual Property Law, 1600 Division Street, Suite 500, Nashville,
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`TN 37203, and continuing from day to day thereafter until completed. The deposition will be
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`conducted before an officer authorized by law to administer oaths and will be recorded by
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`stenographic, sound, video, audiovisual, and/or any other appropriate means. The deposition will
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`be taken for the purposes of discovery, for use at trial in these actions, and for any purposes
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`permitted under the Federal Rules of Civil Procedure. You are invited to attend and participate.
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`
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`

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`Case 1:17-cv-00770-JDW-MPT Document 170 Filed 03/10/23 Page 2 of 2 PageID #: 15437
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`POTTER ANDERSON & CORROON LLP
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`By: /s/ Bindu A. Palapura
`Bindu A. Palapura (#5370)
`Andrew L. Brown (#6766)
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`bpalapura@potteranderson.com
`abrown@potteranderson.com
`
`
`Attorneys for Defendant Caterpillar Inc.
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`
`
`
`OF COUNSEL:
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`James C. Yoon
`Christopher D. Mays
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`Telephone: (650) 493-9300
`
`Ryan R. Smith
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104
`Telephone: (206) 883-2500
`
`Lucy Yen
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`1301 Avenue of the Americas, 40th Floor
`New York, NY 10019
`Telephone: (212) 999-5800
`
`Erik J. Carlson
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Telephone: (323) 210-2900
`
`Dated: March 10, 2023
`10682261 /11898.00005
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`-2-
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`

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