`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 17-770-JDW
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`WIRTGEN AMERICA, INC.,
`
`Plaintiff,
`
`v.
`
`CATERPILLAR INC.,
`
`Defendant.
`
`DEFENDANT’S NOTICE OF 30(b)(1) DEPOSITION OF DR. GÚNTER HAHN
`
`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
`
`PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules of Civil
`
`Procedure and the applicable Local Civil Rules of the United States District Court for the District
`
`of Delaware, Defendant and Counterclaim-Plaintiff Caterpillar Inc. (“Caterpillar”), by and through
`
`their attorneys, will take the deposition upon oral examination of Dr. Gúnter Hahn on February 2,
`
`2024 at 9:00 a.m. EST, the date and time mutually agreed upon by the parties, at Wilson Sonsini
`
`Goodrich & Rosati, P.C., 222 Delaware Avenue, Suite 800, Wilmington, DE 19801-5225, and
`
`continuing from day to day thereafter until completed. The deposition will be conducted before
`
`an officer authorized by law to administer oaths and will be recorded by stenographic, sound,
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`video, audiovisual, and/or any other appropriate means. The deposition will be taken for the
`
`purposes of discovery, for use at trial in these actions, and for any purposes permitted under the
`
`Federal Rules of Civil Procedure. You are invited to attend and participate.
`
`
`
`Case 1:17-cv-00770-JDW Document 286 Filed 01/19/24 Page 2 of 2 PageID #: 29563
`
`Respectfully submitted,
`POTTER ANDERSON & CORROON LLP
`
`By: /s/ Andrew L. Brown
`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.
`
`OF COUNSEL:
`
`James C. Yoon
`Ryan R. Smith
`Christopher D. Mays
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`Telephone: (650) 493-9300
`
`Lucy Yen
`Cassie Leigh Black
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`1301 Avenue of the Americas, 40th Floor
`New York, NY 10019
`Telephone: (212) 999-5800
`
`Dated: January 19, 2024
`11278666/11898.00005
`
`-2-
`
`
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