e.Digital Corporation v. Micron Consumer Products Group, Inc.

• Assigned to: Judge Marilyn L. Huff
• Referred to: Magistrate Judge Bernard G. Skomal

04/20/2015 69 RESPONSE in Opposition re 64 MOTION filed by e.Digital Corporation. (Attachments: # 1 Declaration of Anton N. Handal, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S)(Handal, Anton) (Entered: 04/20/2015)

04/20/2015 70 RESPONSE re 69 Response in Opposition to Motion, Amended Exhibit N to the Declaration of Anton N. Handal Submitted In Support Of Plaintiff e.Digital Corporations Opposition To Micron Defendants Motion Seeking Modification Of The Consolidated Scheduling Order And For Leave To Amend Answer And Counterclaims filed by e.Digital Corporation. (Handal, Anton) (Entered: 04/20/2015)

Document 69: https://drive.google.com/file/d/0Bx9NLDCScshndGV6NklyTUtQM28/view?usp=sharing

Special Note: Please read document 69, Handal lays it on the line, and tells it like it is.... in my opinion.

It is not true that the Defendants have been diligent or that they only recently discovered the existence of this supposed defense. Such assertions are unbelievable given that discovery has been ongoing in this case since at least August of 2014. Defendants have dragged their feet in discovery, having waited until November of 2014 (11 months after these cases were filed) to propound any discovery whatsoever.