`
`C.A. No. 2023-1060-NAC
`
`D1 JASPER HOLDINGS LP, D1 SPV
`JL MASTER LP, JAY BLOCKER
`LTD., JAY DOMESTIC LLC, GCCU
`II LLC, TOCU XX LLC, OC II FIE
`VIII LP, JL SPV HOLDINGS, LLC,
`EMS J-INV LLC, DISRUPTIVE
`TECHNOLOGY SOLUTIONS XIV,
`LLC, DISRUPTIVE TECHNOLOGY
`SOLUTIONS XVI, LLC–SERIES A,
`DISRUPTIVE TECHNOLOGY
`SOLUTIONS XVI, LLC–SERIES B,
`and DISRUPTIVE TECHNOLOGY
`SOLUTIONS XVI, LLC–SERIES C,
`Plaintiffs,
`
`v.
`JUUL LABS, INC. and JL TAO LLC,
`Defendants.
`
`STIPULATION AND [PROPOSED] ORDER GOVERNING
`BRIEFING ON PLAINTIFFS’ MOTION TO COMPEL
`AND THE PARTIES’ POST-TRIAL BRIEFS
`
`WHEREAS, a two-day trial in the above-captioned action (the “Action”) was
`
`conducted on March 13 and 14, 2024;
`
`WHEREAS, post-trial argument has been scheduled for July 8, 2024,
`
`beginning at 9:15 a.m. EST;
`
`WHEREAS, on Friday, March 22, 2024, Plaintiffs filed a Motion to Compel,
`
`Or In the Alternative, To Strike (the “Motion to Compel”) (D.I. 261);
`
`WHEREAS, argument on the Motion to Compel has been scheduled for April
`
`26, 2024 at 1:30 p.m. EST; and
`
`EFiled: Apr 04 2024 05:02PM EDT
`Transaction ID 72679457
`Case No. 2023-1060-NAC
`
`
`
`WHEREAS, Plaintiffs and Defendants (together, the “Parties”) have met and
`
`conferred concerning a schedule to govern briefing on the Motion to Compel and
`
`post-trial briefing;
`
`IT IS HEREBY STIPULATED AND AGREED, by and between the Parties,
`
`subject to approval of the Court, as follows:
`
`1.
`
`Defendant JUUL Labs, Inc. shall file an opposition to the Motion to
`
`Compel by April 9, 2024 at 5 p.m. EST.
`
`2.
`
`Plaintiffs shall file a reply in further support of the Motion to Compel
`
`by April 19, 2024 at 5 p.m. EST.
`
`3.
`
`Plaintiffs shall file an opening post-trial brief by April 30, 2024 at
`
`5 p.m. EST. At the same time, Plaintiffs shall file proposed findings of fact with
`
`detailed citations to the record.
`
`4.
`
`Defendants shall file an answering post-trial brief by June 4, 2024 at 5
`
`p.m. EST. At the same time, Defendants shall file proposed findings of fact with
`
`detailed citations to the record.
`
`5.
`
`The Parties’ proposed findings of fact shall not count toward the word
`
`limit otherwise applicable under Court of Chancery Rule 171(f).
`
`6.
`
`Plaintiffs shall file a post-trial reply brief by June 25, 2024 at 5 p.m.
`
`EST.
`
`2
`
`
`
`OF COUNSEL:
`
`Martin Flumenbaum
`Jeffrey J. Recher
`Nina Kovalenko
`PAUL, WEISS, RIFKIND,
` WHARTON & GARRISON LLP
`1285 Avenue of the Americas
`New York, NY 10019-6064
`(212) 373-3000
`
`
`
`PAUL, WEISS, RIFKIND,
` WHARTON & GARRISON LLP
`
`/s/ Daniel A. Mason
`Daniel A. Mason (#5206)
`Sabrina M. Hendershot (#6286)
`Elizabeth Wang (#6620)
`1313 North Market Street, Suite 806
`Post Office Box 32
`Wilmington, DE 19899-0032
`(302) 655-4410
`
`Attorneys for Plaintiffs D1 Jasper
`Holdings LP, D1 SPV JL Master LP,
`Jay Blocker Ltd., Jay Domestic LLC,
`GCCU II LLC, TOCU XX LLC, OC II
`FIE VIII LP, JL SPV Holdings, LLC,
`EMS J-INV LLC, Disruptive
`Technology Solutions XIV, LLC,
`Disruptive Technology Solutions XVI,
`LLC–Series A, Disruptive Technology
`Solutions XVI, LLC–Series B, and
`Disruptive Technology Solutions XVI,
`LLC–Series C
`
`3
`
`
`
`
`
`
`
`OF COUNSEL:
`
`Roger A. Cooper
`Lina Bensman
`CLEARY GOTTLIEB STEEN
`& HAMILTON LLP
`One Liberty Plaza
`New York, New York 10006
`(212) 225-2000
`
`MORRIS, NICHOLS, ARSHT
` & TUNNELL LLP
`
`/s/ David J. Teklits
`William M. Lafferty (#2755)
`David J. Teklits (#2432)
`Alexandra M. Cumings (#6146)
`Grant E. Michl (#7088)
`Kirk C. Andersen (#7156)
`1201 North Market Street, 16th Floor
`Wilmington, DE 19801
`(302) 658-9200
`
`Attorneys for Defendant JUUL
`Labs, Inc.
`
`RICHARDS, LAYTON & FINGER, P.A.
`
`OF COUNSEL:
`
`Robert A. Weikert
`Andrew H. Winetroub
`NIXON PEABODY LLP
`One Embarcadero Center, 32nd Floor
`San Francisco, California 94111
`(415) 984-8200
`
`/s/ Richard P. Rollo
`Richard P. Rollo (#3994)
`Susan Hannigan Cohen (#5342)
`Travis S. Hunter (#5350)
`John M. O’Toole (#6448)
`One Rodney Square
`920 North King Street
`Wilmington, Delaware 19801
`(302) 651-7700
`
`Dated: April 4, 2024
`
`Attorneys for Defendant JL Tao LLC
`
`IT IS SO ORDERED this _____ day of __________, 2024.
`
`Vice Chancellor Nathan A. Cook
`
`4
`
`
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