Pacer,e.Digital’s Objection to GoPro reply &GoPro joinder for the same reason !
in response to
by
Message: To those who would like to come to an agreement with apple.
ANTON HANDAL (Bar No. 113812) anh@handal-law.com PAMELA C. CHALK (Bar No. 216411) pchalk@handal-law.com GABRIEL HEDRICK (Bar No. 220649) ghedrick@handal-law.com 1200 Third Avenue, Suite 1321 San Diego, California 92101 Tel: 619.544.6400 Fax: 619.696.0323 Attorneys for Plaintiff and Counter-Defendant, e.Digital Corporation UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation, Plaintiff, v. Woodman Labs, Inc. dba GoPro, Defendant.
And Related Counterclaims. Case No. 3:12-cv-02899-DMS(WVG)
E.DIGITAL CORPORATION’S REQUEST FOR JUDICIAL NOTICE AND NOTICE OF OBJECTIONS TO “DEFENDANT’S NOTICE JOINING REPLY BRIEF IN SUPPORT OF MOTION TO AMEND THE STIPULATED PARTIAL JUDGMENT AND RESPONSE TO OBJECTION TO DECLARATION OF BRYAN A. KOHM” (SUBMITTED IN SUPPORT OF OPPOSITION TO “APPLE’S NOTICE OF MOTION AND MOTION TO AMEND THE STIPULATED PARTIAL JUDGMENT TO CERTIFY THE COLLATERAL ESTOPPEL ORDER FOR IMMEDIATE APPEAL” AND GOPRO’S JOINDER THEREIN) Date: December 20, 2013 Time: 1:30 p.m. Ctrm: 13A (Annex) Judge: Hon. Judge Dana M. Sabraw
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA: Plaintiff and Counter-Defendant e.Digital Corporation (“Plaintiff” or “e.Digital”), by and through its attorney, hereby respectfully requests the Court to take judicial notice pursuant to Federal Rule of Evidence 201 and/or all other applicable provisions of law of the following facts: 1) On December 6, 2013, Defendant Apple Inc. filed the following reply documents (collectively referred to herein as the “Apple Reply”) in support of its motion to amend in the case
, Case No. 3:13-cv-
00785-DMS-WVG (“Apple matter”): a)
“Defendants’ Reply In Support Of Motion To Amend The
Stipulated Partial Judgment To Certify The Collateral Estoppel Order
” (Dkt #66);
b) “
Declaration Of Kevin J. O’Shea In Support Of Reply In
Support Of Defendants’ Reply In Support Of Motion To Amend The Stipulated Partial Judgments To Certify The Collateral Estoppel Order For Immediate Appeal,
(Dkt #66-1);
c) Exhibit 4 to the “
Declaration Of Kevin J. O’Shea In Support Of
Reply In Support Of Defendants’ Reply In Support Of Motion To Amend The Stipulated Partial Judgments To Certify The Collateral Estoppel Order For Immediate Appeal
(Dkt #66-2);
and, d) Exhibit 5 to the “
Declaration Of Kevin J. O’Shea In Support Of
Reply In Support Of Defendants’ Reply In Support Of Motion To Amend The Stipulated Partial Judgments To Certify The Collateral Estoppel Order For Immediate Appeal (Dkt #66-3)
2) The Defendant and Counterclaimant in this case, Woodman Labs, Inc. dba GoPro (“GoPro”), filed the document entitled “
Defendant’s Notice Joining
Reply Brief In Support Of Motion To Amend The Stipulated Partial Judgment And Response To Objection To Declaration Of Bryan A. Kohm”
(“GoPro Reply”)
in this matter on or about December 6, 2013. (Dkt #76 in the GoPro matter). 3) On December 9, 2013, e.Digital filed “
Plaintiff e.Digital
Corporation's Exhibit A In Support Of Objections And Objections To Portions Of “Defendants’ Reply In Support Of Motion To Amend The Stipulated Partial Judgment To Certify The Collateral Estoppel Order”; Portions Of The “Declaration Of Kevin J. O’Shea In Support Of Reply In Support Of Defendants’ Reply In Support Of Motion To Amend The Stipulated Partial Judgments To Certify The Collateral Estoppel Order For Immediate Appeal” And Exhibits 4-5 Attached Thereto
”, (“e.Digital’s Objections”) in the Apple matter, a
copy of which is attached hereto as Exhibit 1. (Dkt #67 in the Apple matter).
NOTICE is given that e.Digital Corporation objects to the GoPro Reply
and/or GoPro joinder in the Apple Reply for the same reasons and on the same
basis as stated in e.Digital’s Objections to the Apple Reply, which consists of the
document attached hereto as Exhibit 1.
It is respectfully requested that e.Digital’s Objections be sustained in both
the Apple matter and GoPro matter.
Respectfully submitted,
HANDAL & ASSOCIATES By: /s/Pamela C. Chalk Anton N. Handal Gabriel G. Hedrick Pamela C. Chalk Attorneys for Plaintiff e.Digital Corporation
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