Epic Systems Corporation v. Tata Consultancy Services Limited et al
| Epic Systems Corporation |
| Tata Consultancy Services Limited and Tata America International Corporation d/b/a TCA America |
| Stroz Friedberg, LLC |
| 3:2014cv00748 |
| October 31, 2014 |
| US District Court for the Western District of Wisconsin |
| Madison Office |
| Dane |
| William M Conley |
| Stephen L Crocker |
| Other Statutory Actions |
| 18 U.S.C. § 1030 Computer Fraud and Abuse Act |
| Both |
Docket Report
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This docket was last retrieved on September 6, 2022. A more recent docket listing may be available from PACER.
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Filing 1055
Notice of Withdrawal of Counsel by Martha Jahn Snyder re: Plaintiff Epic Systems Corporation (Snyder, Martha)
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USCA Case Number 22-2420 for #1051 Notice of Appeal, filed by Tata Consultancy Services Limited, Tata America International Corporation. (jat)
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Filing 1054
Notice of Withdrawal of Counsel by Martha Jahn Snyder re: Plaintiff Epic Systems Corporation (Notice of Withdrawal of Anthony A. Tomaselli and Anita Marie Boor) (Snyder, Martha)
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Filing 1053
Transmission of Notice of Appeal, Order, Amended Judgment and Docket Sheet to Seventh Circuit Court of Appeals re: #1051 Notice of Appeal, (Attachments: #1 Order, #2 Amended Judgment, #3 Docket Sheet) (lak)
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Filing 1052
Appeal Information Packet. (lak)
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Filing 1051
NOTICE OF APPEAL by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited as to #1046 Judgment, #1045 Order. Filing fee of $ 505, receipt number AWIWDC-3104582 paid. No Docketing Statement filed. (Egleson, Christopher)
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Filing 1050
ORDER granting #1049 Proposed Amended Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal. Signed by District Judge William M. Conley on 7/28/22. (jat)
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Filing 1049
Proposed Amended Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Trela, Constantine) Modified on 7/27/2022. (lak)
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Filing 1048
Status Report / Parties' Joint Status Report Regarding Post-judgment Security by Plaintiff Epic Systems Corporation (Saros, Nick)
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Filing 1047
** TEXT ONLY ORDER ** In light of the court's entry of an amended judgment, the parties are directed to confer and submit a joint proposal, by July 19, 2022, on how the court should modify defendants' post-judgment security obligation. Defendants' current motion to vacate the order regarding post-judgment security, dkt. #1043 , is MOOT. Signed by District Judge William M. Conley on 7/12/2022. (rks)
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Filing 1046
AMENDED JUDGMENT in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International Corporation as to plaintiff's claims for breach of contract, violations of the Computer Fraud and Abuse Act, 19 U.S.C. 1030(g) claims, violations of the Wisconsin Computer Crimes Act, Wis. Stat. 943. 70(2)(a), fraudulent misrepresentation, misappropriation of trade secrets, unfair competition, unjust enrichment and deprivation of property; in favor of defendants Tata Consultancy Services Limited and Tata America International Corporation against plaintiff Epic Systems Corporation as to plaintiff's conversion claim; in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International Corporation dismissing defendants' counterclaims; in favor of plaintiff Epic Systems Corporation against Tata Consultancy Services Limited and Tata America International Corporation in the amount of $280,000,000.00. (WMC /rks) (rks).
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Filing 1045
ORDER that: The jury's award of punitive damages is reduced to $140 million. The clerk of court is directed to file an amended final judgment, replacing the fourth paragraph of the original judgment with the following language:IT IS FURTHER ORDERED AND ADJUDGED that judgment is entered in favor of plaintiff Epic Systems Corporation against Tata Consultancy Services Limited and Tata America International Corporation in the amount of $280,000,000.00. In all other respects, the court's original, final judgment remains unchanged. Signed by District Judge William M. Conley on 6/30/2022. (rks)
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Filing 1044
Brief in Opposition by Plaintiff Epic Systems Corporation re: #1043 Motion to Vacate, filed by Tata Consultancy Services Limited, Tata America International Corporation (Attachments: #1 Exhibit A - TCS Financial Data) (Saros, Nick)
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Filing 1043
Motion to Vacate Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 6/23/2022. (Attachments: #1 Exhibit 1 - Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal) (Trela, Constantine)
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Filing 1042
Brief in Reply by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited in Support of Dummy Motion - No NEFS TCS's Post-Remand Reply Brief on Punitive Damages (Attachments: #1 Exhibit A - Redline Comparison of Opinions) (Trela, Constantine)
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Filing 1041
Response re: 1039 Order on Stipulation, 1036 Order on Motion for Hearing,,, Epic Systems' Memorandum Regarding Entry of Punitive Damages Award by Plaintiff Epic Systems Corporation. (Attachments: #1 Exhibit A - Excerpts from TCS Reports and Communications, #2 Exhibit B - TCS Management Listing) (Richmond, Rick)
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Filing 1040
Post-Remand Opening Brief on Punitive Damages by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Trela, Constantine) Modified on 1/14/2021. (lak)
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Filing 1039
** TEXT ONLY ORDER **The parties' joint stipulation to extend the post-remand briefing schedule (dkt. #1038 ) is GRANTED. Defendants' opening brief explaining why the court should not award $140 million in punitive damages is now due January 13, 2021; plaintiff's response is due February 10, 2021; and defendants' reply is due February 24, 2021. Signed by District Judge William M. Conley on 12/14/2020. (kwf)
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Filing 1038
Joint Stipulation to Extend Post-Remand Briefing Schedule by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Mandell, Jeffrey)
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Filing 1037
USCA JUDGMENT affirming in part, vacating and remanding as to #1026 Notice of Appeal filed by Epic Systems Corporation, #1023 Notice of Appeal filed by Tata Consultancy Services Limited, Tata America International Corporation. Entire record consisting of 1 CD returned. (Attachments: #1 Appellate Opinion, #2 Amended Appellate Opinion, #3 Denial of Rehearing, #4 Second Denial of Rehearing, #5 Mandate) (kwf)
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Punitive Damages. (kwf)
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Filing 1036
** TEXT ONLY ORDER **The court is in receipt of plaintiff Epic Systems Corporation's motion for hearing. (Dkt. #1035 .) Since the court has not yet received the mandate from the Seventh Circuit, plaintiff's motion is premature at best and must be DENIED for lack of jurisdiction. Regardless, the court sees no reason for a hearing, and instead will set the following briefing schedule: within 21 days of the receipt of the mandate in this court, defendants Tata Consultancy Services Limited and Tata America International Corporation may file a brief explaining why the court should not award $140 million in punitive damages; plaintiff may file a response 14 days thereafter; and defendants may file a reply 7 days after plaintiff's response. Signed by District Judge William M. Conley on 11/30/2020. (kwf)
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Filing 1035
Motion for Hearing by Plaintiff Epic Systems Corporation (Request for a Post-Remand Status Conference). (Richmond, Rick) Modified on 11/30/2020. (lak)
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Filing 1034
Joint Notice by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: Preparation of Record on Appeal. (Trela, Constantine) Modified on 12/6/2019. (lak)
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Filing 1033
ORDER on Bill of Costs: Costs Taxed in favor of Plaintiff in the amount of $721,646.36. Signed by Peter A. Oppeneer, Clerk of Court on 4/17/19. (jat)
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Filing 1032
Court Reporter Certification of Seventh Circuit Transcript Information Sheet re: #1026 Notice of Appeal. (kwf)
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Filing 1031
Transcript Request Form by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 1030
Court Reporter Certification of Seventh Circuit Transcript Information Sheet re: #1023 Notice of Appeal. (kwf)
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Filing 1029
Transcript Request Form by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Trela, Constantine)
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Filing 1028
Transmission of Cross Notice of Appeal, Orders, Judgment and Docket Sheet to Seventh Circuit Court of Appeals re: #1026 Cross Notice of Appeal, (Attachments: #1 Order No.: 976, #2 Judgment No.: 978, #3 Opinion and Order No.: 1022, #4 Docket Sheet) (lak)
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Filing 1027
Appeal Information Packet. (lak)
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Filing 1026
CROSS NOTICE OF APPEAL by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation as to #1022 Order on Motion for Judgment as a Matter of Law, #976 Order on Motion for Judgment as a Matter of Law, Order on Motion for Attorney Fees, Order on Motion to Strike, Order on Motion for Leave to File, Order on Motion to Amend/Correct, Order on Motion for Clarification, Order on Motion for Hearing, #978 Judgment. Filing fee of $ 505, receipt number 0758-2437935 paid. No Docketing Statement filed. (Richmond, Rick)
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USCA Case Number 19-1613 for #1026 Notice of Appeal, filed by Epic Systems Corporation. (kwf)
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Filing 1025
Transmission of Notice of Appeal, Orders, Judgment and Docket Sheet to Seventh Circuit Court of Appeals re: #1023 Notice of Appeal, (Attachments: #1 Amended Opinion and Order No.: 944, #2 Order No.: 976, #3 Order No.: 977, #4 Judgment No.: 978, #5 Opinion and Order No.: 1022, #6 Docket Sheet) (lak)
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Filing 1024
Appeal Information Packet. (lak)
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USCA Case Number 19-1528 for #1023 Notice of Appeal, filed by Tata Consultancy Services Limited, Tata America International Corporation. (kwf)
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Filing 1023
NOTICE OF APPEAL by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited as to #977 Order, #944 Order, #1022 Order on Motion for Judgment as a Matter of Law, #976 Order on Motion for Judgment as a Matter of Law, Order on Motion for Attorney Fees, Order on Motion to Strike, Order on Motion for Leave to File, Order on Motion to Amend/Correct, Order on Motion, Order on Motion for Clarification, Order on Motion for Hearing, #978 Judgment. Filing fee of $ 505, receipt number 0758-2431094 paid. No Docketing Statement filed. (Trela, Constantine)
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Filing 1022
OPINION AND ORDER denying #996 motions for judgment as a matter of law pursuant to Fed. R. Civ. Proc. 50(b), for a new trial pursuant to Fed. R. Civ. Proc. 59 and for reconsideration of dismissal of counterclaims pursuant to Fed. R. Civ. Proc. 60. Signed by District Judge William M. Conley on 3/22/2019. (kwf)
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Filing 1021
ORDER granting #1019 Motion for Clarification, but denying the requested relief either to find that provision of the injunction is still active or to extend the timeframe. Signed by District Judge William M. Conley on 8/3/2018. (kwf)
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Filing 1020
Declaration of Brett Rehm filed by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation in Support re: #1019 Motion for Clarification. (Saros, Nick) Modified on 8/2/2018. (lak)
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Filing 1019
Motion for Clarification of the Time Period Alloted for the Court-Appointed Monitor as Stated in the Amended Permanent Injunction by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 8/2/2018. (lak)
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Filing 1018
** TEXT ONLY ORDER **ORDER granting #1017 Motion to Withdraw as Attorney. Attorney Kelly M. Morrison terminated. Signed by Magistrate Judge Stephen L. Crocker on 5/9/2018. (kwf)
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Filing 1017
Motion to Withdraw as Attorney (Kelly M. Morrison) by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation. Response due 5/16/2018. (Morrison, Kelly)
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Filing 1016
Brief in Reply in Opposition to Bill of Costs by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #1004 Bill of Costs filed by Epic Systems Corporation. (Robben, Philip)
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Filing 1015
Supplemental Declaration of Nick G. Saros re: #1004 Bill of Costs, (Attachments: #1 Exhibit K - Deposition Invoices, #2 Exhibit L - Hotel Invoice, #3 Exhibit M - Outside Printing Invoices, #4 Exhibit N - ESI Invoices Not Requested, #5 Exhibit O - ESI Invoices Requested) (Saros, Nick) Modified on 12/21/2017: Linked to the pending motion instead of the brief. (lak)
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Filing 1014
Brief in Support of Bill of Costs by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation re: #1004 Bill of Costs filed by Epic Systems Corporation. (Saros, Nick)
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Filing 1013
Brief in Reply by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Support of #996 Motion for Judgment as a Matter of Law or, in the Alternative, a New Trial or Remittitur and to Vacate the Court's Order Granting Epic's Motion to Dismiss, Pursuant to Federal Rules of Civil Procedure 50 (b), 59, and 60(b). (Robben, Philip) Modified on 12/18/2017. (lak)
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Filing 1012
** TEXT ONLY ORDER **The parties' stipulation #1011 is accepted and then some: the new deadline is January 5, 2018. Signed by Magistrate Judge Stephen L. Crocker on 12/13/2017. (kwf)
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Filing 1011
Joint Stipulation for Extension of Time to File Reply Brief in Support of Opposition to Epic's Bill of Costs by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 1010
Objection to Bill of Costs by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #1004 Bill of Costs filed by Epic Systems Corporation. (Robben, Philip)
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Filing 1009
** TEXT ONLY ORDER **The court has filed under seal the agreed order regarding security during post-judgment proceedings and appeal with attachments. The parties have until December 7, 2017, to explain why the court should not unseal the order itself (while keeping the attachments under seal). Absent any response, the court will unseal the order after that date. Additionally, the telephonic hearing at 2:00 p.m. on December 1, 2017 is removed from the court's calendar. Signed by District Judge William M. Conley on 12/1/2017. (kwf)
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Filing 1008
AGREED ORDER Regarding Security During Post-Judgment Proceedings and Appeal. Signed by District Judge William M. Conley on 11/30/2017. (Attachments: #1 Exhibit A - Form of Letter of Credit (Sealed), #2 Exhibit B - Form of JPMorgan Chase Bank, N.A. Escrow Agreement (Sealed)) (kwf) Modified on 12/12/2017. (lak)
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Filing 1007
Brief in Opposition by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation re: #996 Motion for Judgment as a Matter of Law, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Richmond, Rick)
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Filing 1006
Declaration of Nick G. Saros re: #1004 Bill of Costs, (Attachments: #1 Exhibit A - Summons and Subpoena Costs, #2 Exhibit B - Jenner Deposition Costs, #3 Exhibit C - Quarles Deposition Costs, #4 Exhibit D - Deposition Costs Chart, #5 Exhibit E - Court Transcription Costs, #6 Exhibit F - Outside Vendor Printing Costs, #7 Exhibit G - Jenner Copying Costs, #8 Exhibit H - Alphagraphics Copying and Exemplification Costs, #9 Exhibit I - Visual Advantage Exemplification Costs, #10 Exhibit J - Taxable E Discovery Costs) (Saros, Nick)
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Filing 1005
Corrected Redaction to #1002 Notice. (Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal) by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - Form Letter of Credit, #2 Exhibit B - Form of Escrow Agreement) (Richmond, Rick)
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Filing 1004
Bill of Costs by Counter Defendant Epic Systems Corporation, Plaintiff Epic Systems Corporation. Motions referred to Peter A. Oppeneer, Clerk of Court. Objection to Bill of Costs due 12/11/2017. Brief in Support to Bill of Costs due 12/20/2017. Brief in Reply in Opposition to Bill of Costs due 12/26/2017. (Saros, Nick)
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Filing 1003
Disregard. See #1005 . Modified on 12/1/2017. (lak/kwf)
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Filing 1002
Notice by Plaintiff Epic Systems Corporation. (Agreed Order Regarding Security During Post-Judgment Proceedings and Appeal), (Sealed Document) (Attachments: #1 Exhibit A - Form of Letter of Credit, #2 Exhibit B - Form of Escrow Agreement) (Richmond, Rick)
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Filing 1001
** TEXT ONLY ORDER **The parties' most recent joint stipulation regarding enforcement of judgment (dkt. #1000 ) is ACCEPTED. Plaintiff's response to defendants' motion to stay execution and approving a letter of credit as appropriate security (dkt. #989 ) is now due November 28, 2017. The parties should be advised that there will be no further extensions. Absent an agreement by the parties, a hearing will be held to address the need for a bond or other assurance of payment at 2:00 p.m. on December 1, 2017. Counsel for defendants to initiate the call to Chambers at 608-264-5087. Signed by District Judge William M. Conley on 11/8/2017. (kwf)
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Filing 1000
Joint Stipulation for Order Regarding Enforcement of Judgment by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 999
** TEXT ONLY ORDER **The court is in receipt of defendants' motion for judgment as a matter of law or, in the alternative, a new trial and to vacate the court's order granting Epic's motion to dismiss, pursuant to Federal Rules of Civil Procedure 50(b), 59 and 60(b). (Dkt. #996 .) Given the length of defendants' supporting brief, it is hardly surprising that a number of the arguments were fully briefed and considered by the court previously, or should have been raised earlier. While plaintiff is free to file a response to all of the arguments raised in defendants' brief, responses to the following arguments that either appear to be new or are more fully developed in defendants' most recent filing are likely to be the most meaningful: sections I.A, I.B, I.D.1, I.F, II.A, II.B, II.C and IV. Signed by District Judge William M. Conley on 11/2/2017. (kwf)
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Filing 998
** TEXT ONLY ORDER **The parties' joint stipulation regarding enforcement of judgment (dkt. #995 ) is ACCEPTED. Plaintiff's response to defendants' motion to stay execution and approving a letter of credit as appropriate security (dkt. #989 ) is now due November 7, 2017. Signed by District Judge William M. Conley on 11/1/2017. (kwf)
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Filing 997
Brief in Support of #996 Motion for Judgment as a Matter of Law, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 996
MOTION FOR JUDGMENT AS A MATTER OF LAW OR, IN THE ALTERNATIVE, FOR A NEW TRIAL OR REMITTITUR, AND TO VACATE THE COURT'S ORDER AND JUDGMENT GRANTING PLAINTIFF'S MOTION TO DISMISS TCS'S COUNTERCLAIMS by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 11/30/2017. Brief in Reply due 12/15/2017. (Robben, Philip)
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Filing 995
Joint Stipulation for Order Regarding Enforcement of Judgment by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 994
** TEXT ONLY ORDER **The parties' joint stipulation regarding enforcement of judgment #993 is ACCEPTED. Plaintiff's response to defendants' motion to stay execution and approving a letter of credit as appropriate security #989 is now due October 31, 2017. Signed by District Judge William M. Conley on 10/26/2017. (arw)
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Reset Briefing Deadlines re: #989 Motion to Stay Execution of Judgment and Approving a Letter of Credit as Appropriate Security. Response due 10/31/2017. (arw)
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Filing 993
Joint Stipulation Regarding Enforcement of Judgment by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 992
** TEXT ONLY ORDER **ORDER accepting #991 Joint Stipulation for Stay Regarding Enforcement of Judgment. Hearing scheduled for 10/18/2017 is canceled. Signed by District Judge William M. Conley on 10/18/17. (jat)
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Filing 991
Joint Stipulation for Stay Regarding Enforcement of Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 990
** TEXT ONLY ORDER ** The court is in receipt of defendants' motion to stay execution of judgment and approving a letter of credit as appropriate security. (Dkt. #989 .) Unless the parties can reach an agreement as to a short continuation of the stay before then, the court will hold a telephonic conference tomorrow, October 18, 2017, at 2:00 p.m. Counsel for Defendant responsible for setting up the call to chambers at (608) 264-5087. Signed by District Judge William M. Conley on 10/17/2017. (mfh)
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Filing 989
Motion to Stay Execution of Judgment and Approving a Letter of Credit as Appropriate Security by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 10/24/2017. (Attachments: #1 Exhibit A - Letter of Credit Form, #2 Exhibit B - Apple Letter of Credit, #3 Exhibit C - October 10, 2017 Email, #4 Exhibit D - October 12, 2017 Email, #5 Exhibit E - October 16, 2017 Email) (Neider, Barbara)
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Filing 988
** TEXT ONLY ORDER **Although the court is hard-pressed to devise arguments TCS can raise in a post-judgment motion or motions that have not already been made and rejected or waived, the parties' joint stipulation regarding enforcement of judgment (dkt. #987 ) is ACCEPTED. Signed by District Judge William M. Conley on 10/13/2017. (kwf)
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Filing 987
Joint Stipulation for Stay of Enforcement of Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 986
** TEXT ONLY ORDER **ORDER granting #985 Motion to Admit Christopher M. Egleson Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 10/5/2017. (lak)
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Filing 985
Motion to Admit Christopher M. Egleson Pro Hac Vice. ( Pro Hac Vice fee $ 100 receipt number 0758-2117065.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Egleson, Christopher)
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Filing 984
** TEXT ONLY ORDER **ORDER granting #981 Motion to Admit Carter Glasgow Phillips Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 10/5/2017. (lak)
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Filing 983
** TEXT ONLY ORDER **ORDER granting #980 Motion to Admit Robert N. Hochman Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 10/5/2017. (lak)
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Filing 982
** TEXT ONLY ORDER **ORDER granting #979 Motion to Admit Constantine L. Trela, Jr., Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 10/5/2017. (lak)
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Filing 981
Motion to Admit Carter Glasgow Phillips Pro Hac Vice. ( Pro Hac Vice fee $ 100 receipt number 0758-2116874.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Phillips, Carter)
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Filing 980
Motion to Admit Robert N. Hochman Pro Hac Vice. ( Pro Hac Vice fee $ 100 receipt number 0758-2116830.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Hochman, Robert)
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Filing 979
Motion to Admit Constantine L. Trela, Jr Pro Hac Vice. ( Pro Hac Vice fee $ 100 receipt number 0758-2116824.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Trela, Constantine)
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Filing 978
JUDGMENT entered in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International Corporation as to plaintiff's claims for breach of contract, violations of the Computer Fraud and Abuse Act, 19 U.S.C. 1030(g) claims, violations of the Wisconsin Computer Crimes Act, Wis. Stat. 943.70(2)(a), fraudulent misrepresentation, misappropriation of trade secrets, unfair competition, unjust enrichment and deprivation of property; in favor of defendants Tata Consultancy Services Limited and Tata America International Corporation against plaintiff Epic Systems Corporation as to plaintiff's conversion claim; in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International. Corporation dismissing defendants' counterclaims; in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International Corporation in the amount of $420,000,000.00; in favor of plaintiff Epic Systems Corporation against defendants Tata Consultancy Services Limited and Tata America International Corporation, permanently enjoining defendants. (WMC/PAO) (kwf)
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Filing 977
ORDER Granting Plaintiff's Motion to Dismiss Counterclaims (dkt. #326). Signed by District Judge William M. Conley on 09/29/2017. (mfh)
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Filing 976
ORDER denying #830 Motion for Judgment as a Matter of Law ; denying #843 Motion for Judgment as a Matter of Law ; granting in part and denying in part #913 Motion for Judgment as a Matter of Law ; denying #916 Motion for Attorney Fees. ; denying as moot #932 Motion to Strike ; denying #934 Motion for Leave to File ; granting #953 Motion to Amend/Correct ; denying as moot #954 Motion for Appointment of a Monitor Pursuant to the Court's April 27, 2016 Injunction and for Other Related Relief ; granting #962 Motion for Clarification. ; denying as moot #968 Motion for Hearing Signed by District Judge William M. Conley on 09/29/2017. (mfh)
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Filing 975
Notice by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #973 Response to Notice of Supplemental Authority. (TCS's Response to Epic's Discussion of the Supreme Court's Goodyear Decision). (Robben, Philip) Modified on 4/30/2017. (lak)
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Filing 974
Redaction to #973 Response to Notice of Supplemental Authority by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/26/2017. (lak)
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Filing 973
Response to Notice of Supplemental Authority by Plaintiff Epic Systems Corporation re: #972 Notice of Supplemental Authority. (Sealed Document) (Richmond, Rick) Modified on 4/26/2017. (lak)
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Filing 972
Notice of Supplemental Authority by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #916 Motion for Attorney Fees and Costs, (Attachments: #1 Exhibit A - Goodyear Tire & Rubber Co v. Haeger et al.) (Robben, Philip) Modified on 4/19/2017. (lak)
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Filing 971
** TEXT ONLY ORDER **Defendants' motion to supplement regarding expert testimony (dkt. #867 ) is GRANTED. The court will address the substance of defendants' challenges to the damages phase of trial in a separate opinion and order on defendants' motion for judgment as a matter of law (dkt. #913 ). Signed by District Judge William M. Conley on 3/22/2017. (kwf)
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Filing 970
** TEXT ONLY ORDER **ORDER granting #969 Motion to Withdraw as Attorney. Attorney Alison Leigh MacGregor terminated. Signed by Magistrate Judge Stephen L. Crocker on 1/6/2017. (kwf)
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Filing 969
Motion to Withdraw as Attorney by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 1/11/2017. (MacGregor, Alison)
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Filing 968
Motion for Hearing (Telephonic Status Conference) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 1/4/2017: Corrected docketing event; dated January 3, 2016. (lak)
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Filing 967
** TEXT ONLY ORDER **ORDER granting #966 Motion to Withdraw as Attorney. Attorney Alina Cristina Mejer terminated. Signed by Magistrate Judge Stephen L. Crocker on 12/21/2016. (kwf)
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Filing 966
Motion to Withdraw as Attorney / Motion to Withdraw Appearance of Attorney Alina C. Mejer by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 12/28/2016. (Robben, Philip)
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Filing 965
Brief in Opposition by Plaintiff Epic Systems Corporation re: #962 Motion for Clarification, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Richmond, Rick)
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Filing 964
Redaction to #963 Brief in Support, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 963
Brief in Support of #962 Motion for Clarification, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip)
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Filing 962
Motion for Clarification re: #959 Order on Motion for Permanent Injunction, Order on Motion for Extension of Time, Order on Motion for Miscellaneous Relief, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 12/8/2016. (Robben, Philip)
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Filing 961
Redaction to #960 Brief in Opposition, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 960
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #954 Motion for Appointment of a Monitor Pursuant to the Court's April 27, 2016 Injunction and for Other Related Relief filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 11/9/2016. (lak)
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Filing 959
OPINION AND ORDER granting in part and denying in part #911 Motion to Modify Permanent Injunction; granting #915 Motion for Extension of Time Regarding the Submission Regarding the Appointment of a Monitor. The court appoints Samuel Rubin of Stroz Friedberg, LLC as the monitor as described in 4 of the Amended Permanent Injunction. Signed by District Judge William M. Conley on 11/2/2016. (kwf)
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Filing 958
Redaction to #956 Declaration of Rick Richmond by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Slipsheet, #2 Exhibit 2 - Slipsheet, #3 Exhibit 3 - Slipsheet, #4 Exhibit 4 - Slipsheet) (Richmond, Rick)
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Filing 957
Redaction to #955 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 956
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #954 Motion for Appointment of a Monitor Pursuant to the Court's April 27, 2016 Injunction and for Other Related Relief, (Sealed Document) (Attachments: #1 Exhibit 1 - June 2016 Correspondence from Brindha Selliah to the Court, #2 Exhibit 2 - 7/8/2016 Email Attaching Epic's Response to Brindha Selliah's Request, #3 Exhibit 3 - 7/8/2016 Saros Declaration in Support of Epic's Response to Brindha Selliah's Request, #4 Exhibit 4 - 7/11/2016 Email Attaching TCS's Response to Brindha Selliah's Request) (Richmond, Rick) Modified on 11/2/2016. (lak)
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Filing 955
Brief in Support of #954 Motion for Appointment of a Monitor Pursuant to the Court's April 27, 2016 Injunction and for Other Related Relief by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 954
Motion for Appointment of a Monitor Pursuant to the Court's April 27, 2016 Injunction and for Other Related Relief by Plaintiff Epic Systems Corporation. Response due 11/8/2016. (Richmond, Rick) Modified on 11/8/2016 (jls).
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Filing 953
Motion to Amend/Correct re: 952 Order on Motion to Seal. Request for Amendment of the Court's August 17, 2016 Order by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 8/26/2016: Corrected docketing event. (lak)
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Filing 952
** TEXT ONLY ORDER **The court is in receipt of plaintiff Epic Systems Corporation's unopposed motion to seal certain trial exhibits. (Dkt. #946 .) In its brief in support of its motion, Epic details the exhibits it seeks to seal as covering Epic trade secrets and other confidential information concerning software, licensing agreements with third parties, and financial information. Moreover, Epic also seeks to seal exhibits produced by third parties, most notably Epic's client Kaiser, and exhibits containing personal information of its employee Philippe Guionnet. Pursuant to Fed. R. Civ. P. 26(c)(1)(G), the court finds plaintiff has demonstrated good cause for maintaining these exhibits under seal. See also Jessup v. Luther, 277 F.3d 926, 929 (7th Cir. 2002) (explaining that sealing of certain information may be warranted "in order to protect trade secrets or other compelling interests in secrecy). As such, the motion is GRANTED. The following exhibits are to be maintained under seal: 4, 4A, 39, 169, 188, 199, 199A, 209, 211, 258, 259, 270, 271, 307, 309, 427A, 433, 436, 436A, 437, 437A, 438, 440, 536, 700, 801, 833, 860, 1008, 1247, 2003, 2004, 2020, 2093, 2094, 2100, 2101, 2105, 2126, 2128, and 2234. Signed by Magistrate Judge Stephen L. Crocker on 8/17/2016. (kwf)
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Filing 951
Response Stating No Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #946 Motion to Seal filed by Epic Systems Corporation. (MacGregor, Alison)
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Set Briefing Deadlines as to #946 Motion to Seal Certain Trial Exhibits. Response due 8/16/2016. (kwf/bgw)
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Filing 950
Exhibit to #947 Brief in Support filed by Epic Systems Corporation, #946 Motion to Seal filed by Epic Systems Corporation. Redacted Exhibit 199. (Richmond, Rick) Modified on 8/10/2016. (lak)
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Filing 949
Declaration of Jeffrey S. Roberts filed by Plaintiff Epic Systems Corporation re: #946 Motion to Seal. (Richmond, Rick)
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Filing 948
Declaration of Clement S. Roberts filed by Plaintiff Epic Systems Corporation re: #946 Motion to Seal. (Richmond, Rick)
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Filing 947
Brief in Support of #946 Motion to Seal Certain Trial Exhibits by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 946
Motion to Seal Certain Trial Exhibits by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Richmond, Rick)
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Filing 945
Notice by Plaintiff Epic Systems Corporation re: Sealing Trial Transcript and Exhibits. (Richmond, Rick)
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Filing 944
AMENDED OPINION AND ORDER granting in part and denying in part #195 Motion for Partial Summary Judgment; granting in part and denying in part #197 Motion for Partial Summary Judgment; denying #413 Motion for an Order Denying or Deferring Consideration of Defendants' Partial Motion for Summary Judgment Pursuant to Federal Rule of Civil Procedure 56(d); granting in part and denying in part as moot #448 Motion to Compel Responses to its Fourth Set of Interrogatories; denying #484 Motion to Compel Responses to Defendants' Third Set of Interrogatories; granting in part and reserving in part #326 Motion to Dismiss Defendants' Counterclaims and Immediately Sever and Stay All Counterclaim Proceedings. Signed by District Judge William M. Conley on 7/27/2016. (kwf)
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Filing 943
Redaction to #942 Post Trial Brief by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 7/23/2016. (lak)
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Filing 942
Post Trial Brief. Response to Epic's Response to TCS's Submission of the Declaration of Ajit Menon by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip)
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Filing 941
Post Trial Brief in Opposition to Plaintiff's Request for Judicial Notice by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 7/19/2016: Linked to motion #913 . (lak)
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Filing 940
Redaction to #939 Trial Brief Epic's Response to TCS's Submission of the Declaration of Ajit Menon Regarding Compliance with the Injunction by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 939
Post Trial Brief. Epic's Response to TCS's Submission of the Declaration of Ajit Menon Regarding Compliance with the Injunction by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 938
Post Trial Brief and Request for Judicial Notice of TCS's Recent Statements in Newly Issued 2015-2016 Annual Report and June 17, 2016 Annual Shareholders Meeting by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - TCS Annual Report 2015-2016, #2 Exhibit B - June 19, 2016 Article Reporting on TCS's Annual Meeting, #3 Exhibit C - June 18, 2016 Article Reporting on TCS's Annual Meeting, #4 Exhibit D - TCS Website Confirming Meeting) (Richmond, Rick) Modified on 7/1/2016: Linked to motion #913 . (lak)
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Filing 937
Redaction to #936 Declaration of Ajit Menon by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet) (Robben, Philip) Modified on 6/24/2016. (lak)
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Filing 936
Declaration of Ajit Menon filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #888 Permanent Injunction, (Sealed Document) (Attachments: #1 Exhibit A - List of Keywords) (Robben, Philip)
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Filing 935
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #932 Motion to Strike, filed by Epic Systems Corporation. (Robben, Philip) Modified on 6/23/2016. (lak)
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Filing 934
Motion for Leave to File A Reply Brief In Further Support of Motion for Judgment as a Matter of Law as to Damages and to Strike the Damages Phase Testimony of Thomas Britven and Stirling Martin [dkt. 913] by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 933
Brief in Support of #932 Motion to Strike Those Portions of Defendants' Memorandum of Law in Opposition to Plaintiff's Application for Attorneys' Fees and Costs that Constitute Improper and Untimely Requests for Reconsideration or, in the Alternative, for Leave to File a Short Reply to Address TCS's Arguments by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 6/10/2016. (lak)
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Filing 932
Motion to Strike #927 Brief in Opposition, Those Portions of Defendants' Memorandum of Law in Opposition to Plaintiff's Application for Attorneys' Fees and Costs that Constitute Improper and Untimely Requests for Reconsideration or, in the Alternative, for Leave to File a Short Reply to Address TCS's Arguments by Plaintiff Epic Systems Corporation. Brief in Opposition due 6/23/2016. Brief in Reply due 6/30/2016. (Richmond, Rick) Modified on 6/10/2016. (lak)
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Filing 931
Corrected Declaration of Kristina M. Allen In Support of Defendants' Opposition to Plaintiff's Motion for Attorneys' Fees and Costs filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #916 Motion for Attorney Fees, (Sealed Document) (Attachments: #1 Exhibit 1 - TCS Highlighted Version of Epic Exhibit A Jenner Monthly Invoices [Part 1], #2 Exhibit 1 - TCS Highlighted Version of Epic Exhibit A Jenner Monthly Invoices [Part 2], #3 Exhibit 2 - Summary Analysis of Jenner & Block Monthly Invoices) (Robben, Philip) Modified on 6/6/2016. (lak)
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Filing 930
Redaction to #931 Declaration of Kristina M. Allen by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit 1 - TCS Highlighted Version of Epic Exhibit A Jenner Monthly Invoices, #2 Exhibit 2 - Summary Analysis of Jenner & Block Monthly Invoices) (Robben, Philip) Modified on 6/5/2016. (lak)
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Filing 929
Redaction to #927 Brief in Opposition, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 6/5/2016. (lak)
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Filing 928
Disregard. See #931 . (Sealed Document) Modified on 6/6/2016. (lak)
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Filing 927
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #916 Motion for Attorney Fees filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 926
Brief in Opposition by Plaintiff Epic Systems Corporation re: #913 Motion for Judgment as a Matter of Law, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Richmond, Rick)
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Filing 925
Notice by Plaintiff Epic Systems Corporation. Submission Regarding A Court-Appointed Monitor, (Attachments: #1 Exhibit A - Sam Rubin CV, #2 Exhibit B - Neal Hochberg CV, #3 Exhibit C - Ellen Zimiles and Salvatore LaScala bios, #4 Exhibit D - Saros email With Robben) (Saros, Nick) Modified on 6/2/2016. (lak)
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Filing 924
Redaction to #923 Trial Brief. Memorandum Concerning the Court's Appointment of a Monitor Pursuant to the April 27, 2016, Injunction, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet) (Robben, Philip) Modified on 6/2/2016 (lak).
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Filing 923
Post Trial Brief. Memorandum Concerning the Court's Appointment of a Monitor Pursuant to the April 27, 2016, Injunction by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Sealed Document) (Attachments: #1 Exhibit A - Navigant's Experience) (Robben, Philip) Modified on 6/2/2016. (lak)
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Filing 922
Notice by Plaintiff Epic Systems Corporation of Joint Submission of Clip Reports of Video Testimony Played During Trial. (Attachments: #1 Exhibit 1 - Arun Agarwal, #2 Exhibit 2 - Ramareddy Baddam, #3 Exhibit 3 - Curtis Bajak, #4 Exhibit 4 - Madhusudana Bandarapu, #5 Exhibit 5 - Natarajan Chandrasekaran, #6 Exhibit 6 - Jason Cline, #7 Exhibit 7 - Philippe Guionnet, #8 Exhibit 8 - Sankari Gunasekaran, #9 Exhibit 9 - Anmol Gupta, #10 Exhibit 10 - David Jones, #11 Exhibit 11 - Priscilla Kingston, #12 Exhibit 12 - Ajay Krishnaswamy, #13 Exhibit 13 - Commander Melmangalam Ramanthan Kumar, #14 Exhibit 14 - Mukesh Kumar, #15 Exhibit 15 - Bill McCarthy, #16 Exhibit 16 - Venu Medikonda, #17 Exhibit 17 - Santosh Mohanty, #18 Exhibit 18 - Madhavi Mukherji, #19 Exhibit 19 - Mahendra Pandian, #20 Exhibit 20 - Vishwa Prasad Duddukuru, #21 Exhibit 21 - Venugopal Reddy, #22 Exhibit 22 - Narasimhan Srinivasan, #23 Exhibit 23 - Narasimhan Srinivasan (Rebuttal), #24 Exhibit 24 - Skrikanth Telkapalli, #25 Exhibit 25 - Vikram Vadamalai) (Richmond, Rick)
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Filing 921
** TEXT ONLY ORDER **Defendants' motion for clarification (dkt. #919 ) is GRANTED. The clerk of court is directed the amend the briefing schedule on defendants' motion for judgment as a matter of law (dkt. #913 ) as follows: plaintiff's opposition brief is due 6/3/16. No reply. Signed by District Judge William M. Conley on 5/19/2016. (kwf)
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Filing 920
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #911 Motion for Permanent Injunction filed by Epic Systems Corporation. (Robben, Philip) Modified on 5/17/2016. (lak)
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Filing 919
Motion for Clarification re: 875 Order. Request for clarification regarding the ECF-generated briefing schedule for their motion for judgment as a matter of law and to strike the damages phase testimony of Thomas Britven and Stirling Martin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 5/23/2016. (Robben, Philip)
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Set Briefing Deadlines as to #916 Motion for Attorney Fees and Costs. Brief in Opposition due 6/3/2016. (kwf)
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Filing 918
Redaction to #917 Brief in Support of Epic's Motion for Attorneys' Fees and Costs by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - Slipsheet) (Richmond, Rick)
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Filing 917
Brief in Support of #916 Motion for Attorney Fees and Costs by Plaintiff Epic Systems Corporation, (Sealed Document) (Attachments: #1 Exhibit A - Jenner & Block Monthly Invoices) (Richmond, Rick)
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Filing 916
Motion for Attorney Fees and Costs by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 915
Joint Motion for Extension of Time Regarding the Submission Regarding the Appointment of a Monitor by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Saros, Nick)
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Filing 914
Brief in Support of #913 Motion for Judgment as a Matter of Law as to Damages and to Strike the Damages Phase Testimony of Thomas Britven and Stirling Martin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 5/8/2016. (lak)
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Filing 913
MOTION FOR JUDGMENT AS A MATTER OF LAW as to Damages and to Strike the Damages Phase Testimony of Thomas Britven and Stirling Martin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 6/6/2016. Brief in Reply due 6/20/2016. (Robben, Philip) Modified on 5/8/2016. (lak)
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Filing 912
Notice of Motion by Plaintiff Epic Systems Corporation re: #911 Proposed Amended Permanent Injunction (Redline Proposals). (Richmond, Rick) Modified on 5/5/2016. (lak)
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Filing 911
PROPOSED AMENDED PERMANENT INJUNCTION (Redline Proposals) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 5/5/2016. (lak)
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Filing 910
Corrected Post Trial Brief in Support of Injunctive Relief by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 909
Disregard; refiled as #911 Proposed PERMANENT INJUNCTION (Redline Proposals). Modified on 5/5/2016. (arw)
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Filing 908
Disregard; refiled as #910 Corrected Post Trial Brief in Support of Injunctive Relief. Modified on 5/5/2016. (arw)
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Filing 907
Transcript of Ninth Day of Jury Trial Afternoon Session, held 4/14/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 906
Transcript of Eighth Day of Jury Trial Afternoon Session, held 4/13/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 905
Transcript of Seventh Day of Jury Trial Afternoon Session, held 4/12/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 904
Transcript of Sixth Day of Jury Trial Afternoon Session, held 4/11/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 903
Transcript of Fifth Day of Jury Trial Morning Session, held 4/8/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 902
Transcript of Fourth Day of Jury Trial Morning Session, held 4/7/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 901
Transcript of Third Day of Jury Trial Morning Session, held 4/6/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 900
Transcript of Second Day of Jury Trial Morning Session, held 4/5/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 899
Transcript of First Day of Jury Trial Morning Session, held 4/4/2016 before Chief Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 898
Transcript of Tenth Day of Jury Trial Morning Session, held 4/15/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 897
Transcript of Ninth Day of Jury Trial Morning Session, held 4/14/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 896
Transcript of Eighth Day of Jury Trial Morning Session, held 4/13/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 895
Transcript of Seventh Day of Jury Trial Morning Session, held 4/12/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 894
Transcript of Sixth Day of Jury Trial Morning Session, held 4/11/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 893
Transcript of Fifth Day of Jury Trial Afternoon Session, held 4/8/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 892
Transcript of Fourth Day of Jury Trial Afternoon Session, held 4/7/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 891
Transcript of Third Day of Jury Trial Afternoon Session, held 4/6/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 890
Transcript of Second Day of Jury Trial Afternoon Session, held 4/5/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 889
Transcript of First Day of Jury Trial Afternoon Session, held 4/4/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 888
PERMANENT INJUNCTION. Signed by District Judge William M. Conley on 4/27/2016. (kwf)
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Filing 887
Redaction to #885 Trial Brief. Defendants' Response To Plaintiff's Proposed Injunction by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Version of Proposed Permanent Injunction, #2 Exhibit B - Redline Version of Proposed Permanent Injunction) (Robben, Philip) Modified on 4/26/2016. (lak)
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Filing 886
Disregard. See #887 . Modified on 4/26/2016. (lak)
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Filing 885
Post Trial Brief. Defendants' Response To Plaintiff's Proposed Injunction by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Sealed Document) (Attachments: #1 Exhibit A - Proposed Permanent Injunction, #2 Exhibit B - Redline Version of Proposed Permanent Injunction) (Robben, Philip) Modified on 4/26/2016. (lak)
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Filing 884
** TEXT ONLY ORDER **Plaintiff Epic Systems Corporation's motion for clarification (dkt. #883 ) is GRANTED. No response to defendants' Rule 50(a) motions (dkt. # #830 , #843 ) is required or necessary. The clerk of court is directed to modify the briefing schedule on both motions to reflect that both are now under advisement. Signed by District Judge William M. Conley on 4/25/2016. (kwf)
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Filing 883
Motion for Clarification by Plaintiff Epic Systems Corporation Regarding the ECF-generated Briefing Schedule for Pre-Verdict Rule 50(A) Motions. (Richmond, Rick) Modified on 4/21/2016: Corrected docketing event. (lak)
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Filing 882
** TEXT ONLY ORDER **The court is in receipt of defendants Tata America International Corporation and Tata Consultancy Services Limited's second motion for extension of time to respond to plaintiff Epic Systems Corporation's proposed permanent injunction (dkt. #881 ), which is DENIED. Defendants attempt to justify their request for a further extension by tying it to the date they intend to file their motion on damages. Any relief from the jury's damages award, however, is almost entirely separate from the entry of an injunction -- a remedy to which Epic was entitled on April 13, 2016, when the jury found liability in Epic's favor -- and to the extent related, will be better considered with an actual, permanent injunction in place. Signed by District Judge William M. Conley on 4/20/2016. (kwf)
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Filing 881
Motion for Extension of Time (Additional Extension to Respond to Proposed Injunction) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 4/27/2016. (Neider, Barbara)
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Filing 880
Proposed Permanent Injunction by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/19/2016. (lak)
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Filing 879
Post Trial Brief in Support of Injunctive Relief by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 878
Court Exhibits from Jury Trial held before District Judge William M. Conley. (Attachments: #1 Court Exhibit 1 - Jury Question and Response, #2 Court Exhibit 2 - Jury Note, #3 Court Exhibit 3 - Jury Question, #4 Court Exhibit 4 - Jury Question, #5 Court Exhibit 5 - Jury Question, #6 Court Exhibit 6 - Jury Question, #7 Court Exhibit 7 - Jury Question and Response, #8 Court Exhibit 8 - Jury Note) (arw)
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Filing 877
Trial Exhibit List. (arw)
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Filing 876
Minute Entry for proceedings held before District Judge William M. Conley: Tenth Day of Jury Trial held on 4/15/2016. Damages verdict in the amount of $940,000,000.00 returned in favor of plaintiff Epic Systems Corporation. [4:10] (Court Reporters CS, LS) (arw)
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Filing 875
** TEXT ONLY ORDER **Consistent with the court's directions in open court April 15, 2016, in addition to any deadlines that may apply under the Federal Rules of Civil Procedure for post-verdict motions, defendants may file a challenge to the compensatory and punitive damage verdicts at any time and plaintiff may have twenty-one (21) days to respond. In addition, the following will apply to the court's consideration of any further sanction for defendants' discovery abuses in this case: (1) Epic may have thirty (30) days to file proof of expenses incurred by virtue of the work on discovery in this lawsuit by its lead counsel, Jenner & Block, including a breakout of amounts invoiced and paid for that work, and underlying attorney time records; and (2) TCS may have twenty-one (21) days to object, including its own commensurate information for all timekeepers and firms that represented them during the same period to the extent either the hours, rates or total amount for comparable work is challenged. No reply or proposed reply should be submitted with respect to either the response or objection without advance leave of court. Finally, consistent with the jury's verdict on liability #871 , plaintiff shall submit proposed language for a permanent injunction no later than Monday, April 18, 2016. Defendants' motion for extension of time #874 is GRANTED. Defendants may have until Monday, April 25, 2016, to respond. Signed by District Judge William M. Conley on 4/16/2016. (bgw) Modified on 4/18/2016. (arw)
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Filing 874
Motion for Extension of Time by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 4/22/2016. (Neider, Barbara)
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Filing 873
Supplemental Damages Jury Instructions. (arw)
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Filing 872
Damages Jury Instructions. (arw)
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Filing 871
Jury Verdict - Damages: Verdict returned in favor of Plaintiff Epic Systems Corporation in the amount of $940,000,000.00. (arw)
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Filing 870
Stipulation re: Annual Revenue and Profit (FY15) by Defendants Tata Consultancy Services Limited, Tata America International Corporation. (Doyle, Paul)
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Filing 869
Redaction to #867 Motion to Supplement Regarding Expert Testimony Sealed Document by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Neider, Barbara)
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Filing 868
Minute Entry for proceedings held before District Judge William M. Conley: Ninth Day of Jury Trial held on 4/14/2016. Liability verdict returned in favor of plaintiff Epic Systems Corporation. Trial continues. [4:28] (Court Reporters CS, LS) (arw)
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Filing 867
Motion to Supplement Regarding Expert Testimony Sealed Document by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Mejer, Alina)
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Filing 866
Notice by Plaintiff Epic Systems Corporation Offer of Proof in Support of Epic's Damages Theory Related to the Kaiser Contract, (Sealed Document) (Attachments: #1 Trial Exhibit 0022, #2 Trial Exhibit 0023, #3 Trial Exhibit 0032, #4 Trial Exhibit 0058, #5 Trial Exhibit 0071, #6 Trial Exhibit 0103, #7 Trial Exhibit 0159, #8 Trial Exhibit 0159A, #9 Trial Exhibit 0188, #10 Trial Exhibit 0296, #11 Exhibit - Guionnet Clip Report, #12 Exhibit - Gupta Clip Report, #13 Exhibit - Medikonda Clip Report, #14 Exhibit - Sundar Clip Report) (Richmond, Rick)
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Filing 865
Redaction to #852 Trial Brief in Support of Epic's Unjust Enrichment Damages Theory by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 864
Redaction to #851 Notice (Other) Response to TCS's Offer of Proof Regarding Damages Theories by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 863
Redaction to #862 Deposition Designations Objections and Counter-designations re: Damages by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Objections to Epic's Clip Reports, #2 Exhibit B - Counter-designations) (Neider, Barbara) Modified on 4/15/2016: Corrected docketing event, etc. (lak)
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Filing 862
Deposition Designations Objections and Counter-designations re Damages by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Attachments: #1 Exhibit A - Objections to Epic's Clip Reports, #2 Exhibit B - Counter-designations) (Neider, Barbara) Modified on 4/15/2016. (lak)
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Filing 861
REDACTED ORDER rejecting without prejudice to further order of this court damages proffer by Plaintiff Epic Systems Corporation. Signed by District Judge William M. Conley on 4/14/2016. Signed by District Judge William M. Conley on 4/14/2016. (arw)
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Filing 860
ORDER rejecting without prejudice to further order of this court damages proffer by Plaintiff Epic Systems Corporation. Signed by District Judge William M. Conley on 4/14/2016. (Sealed Document) (arw)
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Filing 859
Deliberation Jury Instructions. (arw)
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Filing 858
Closing Jury Instructions. (arw)
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Filing 857
Introductory Jury Instructions. (arw)
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Filing 856
Jury Instructions: Orientation Remarks and Voir Dire. (arw)
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Filing 855
Jury Verdict - Liability: Verdict returned in favor of Plaintiff Epic Systems Corporation. (arw)
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Filing 854
Notice by Defendants Tata America International Corporation, Tata Consultancy Services Limited (TCS's Response to Epic's Brief in Support of its Unjust Enrichment Theory), (Sealed Document) (Attachments: #1 Exhibit - Britven Demonstratives (Part 1), #2 Exhibit - Britven Demonstratives (Part 2), #3 Exhibit - Britven Demonstratives (Part 3)) (Neider, Barbara) Modified on 4/15/2016. (lak)
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Filing 853
Minute Entry for proceedings held before District Judge William M. Conley: Eighth Day of Jury Trial held on 4/13/2016. Trial continues. [4:16] (Court Reporters CS, LS) (arw)
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Filing 852
Trial Brief in Support of Epic's Unjust Enrichment Damages Theory by Plaintiff Epic Systems Corporation (Sealed Document) (Richmond, Rick)
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Filing 851
Notice by Plaintiff Epic Systems Corporation re: #846 Notice. Response to TCS's Offer of Proof Regarding Damages Theories. (Sealed Document) (Richmond, Rick)
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Set/Reset Trial Date: 10th Day Jury Trial set for 4/15/2016 at 8:00 AM. (arw)
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Filing 850
Notice by Plaintiff Epic Systems Corporation, (Sealed Document) (Attachments: #1 Exhibit 1 - Closing Slides (Richmond, Rick)
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Filing 849
Notice by Plaintiff Epic Systems Corporation (Slides used or referred to by Tom Britven in Epic's Proffer on Damages). (Sealed Document) (Attachments: #1 Exhibit 1 - Tom Britven Proffer Slides, #2 Exhibit 2 - Trial Exhibit 0423) (Richmond, Rick)
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Filing 848
Notice by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit - Closing Slides) (Neider, Barbara)
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Filing 847
Notice by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Offer of Proof Regarding Production of Documents). (Sealed Document) (Attachments: #1 Exhibit - Declaration of Badipatla with Exhibits, #2 Exhibit - Declaration of Erik Laykin with Exhibits) (Neider, Barbara) Modified on 4/14/2016: Declarations were not filed as separate docket entries per Electronic Filing Procedures. (lak)
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Filing 846
Notice by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Offer of Proof Re Damages Theories). (Sealed Document) (Attachments: #1 Exhibit - Supplemental Interrogatory Response of Epic) (Neider, Barbara) Modified on 4/14/2016. (lak)
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Filing 845
Minute Entry for proceedings held before District Judge William M. Conley: Seventh Day of Jury Trial held on 4/12/2016. Evidence entered, trial continues. [7:28] (Court Reporters CS, LS) (arw)
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Set/Reset Trial Date: 9th Day Jury Trial set for 4/14/2016 at 08:00 AM. (voc)
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The parties are directed to file this evening their respective slides used in closing arguments. Plaintiff is also directed to file all slides used or referred to by its expert Thomas Britven in Epic's proffer on damages. Signed by District Judge William M. Conley on 04/13/2016. (bgw)
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Filing 844
Proposed Jury Instructions - Damages. Defendants' Request for a Corrective Instruction Regarding Unjust Enrichment, by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 843
MOTION FOR JUDGMENT AS A MATTER OF LAW by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 5/12/2016. Brief in Reply due 5/27/2016. (Neider, Barbara)
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Filing 842
Brief in Support of #841 Proposed Revisions to Damages Instructions and Verdict by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 4/12/2016. (lak)
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Filing 841
Proposed Jury Instructions - Damages (Revisions to Jury Instructions and Verdict Form Regarding Damages) by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Neider, Barbara)
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Filing 840
Minute Entry for proceedings held before District Judge William M. Conley: Sixth Day of Jury Trial held on 4/11/2016. Evidence entered, trial continues. [7:55] (Court Reporters CS, LS) (arw)
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Filing 839
Notice by Plaintiff Epic Systems Corporation of Epic's proposed curative instructions in response to improper testimony from TCS's expert Eric Laykin. (Sealed Document) (Richmond, Rick)
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Set/Reset Trial Date: 8th Day Jury Trial set for 4/13/2016 at 8:00 AM. (arw)
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Filing 838
Redaction to #832 Joint Stipulation with Respect to Exhibit 2751 by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/12/2016. (lak)
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Filing 837
Redaction to #836 Motion for Clarification by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/12/2016. (lak)
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Filing 836
Motion for Clarification re: #804 Errata Sheet. (Sealed Document) (Richmond, Rick) Modified on 4/12/2016: Corrected docketing event.(lak)
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Filing 835
** TEXT ONLY ORDER **The parties' proposed Exhibit 2751 by joint stipulation for admission as a summary of Exhibit 2098 (dkt. #832 ) is ACCEPTED. Signed by District Judge William M. Conley on 4/11/2016. (kwf)
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Filing 834
** TEXT ONLY ORDER **The parties' joint stipulation to summarize deposition testimony of Ravi Raju and Iyappan Rathina (dkt. #821 ) is ACCEPTED. Signed by District Judge William M. Conley on 4/11/2016. (kwf)
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Filing 833
** TEXT ONLY ORDER **Plaintiff's motion in limine to exclude exhibits and testimony related to the supplemental report of TCS's expert Erik Laykin (dkt. #810 ) is DENIED AS MOOT. Signed by District Judge William M. Conley on 4/11/2016. (kwf)
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Filing 832
Corrected Stipulation to submit Exhibit 2751 to the jury (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 831
Joint Stipulation to submit Exhibit 2751 to the jury (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 830
MOTION FOR JUDGMENT AS A MATTER OF LAW by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 5/11/2016. Brief in Reply due 5/26/2016. (Neider, Barbara)
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Filing 829
Notice by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Proffer With Respect to the Expert Testimony of Erik Laykin). (Sealed Document) (Neider, Barbara)
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Filing 828
** TEXT ONLY ORDER **Order regarding rulings on Bajak deposition designations (dkt. #808 ) is modified, for the reasons explained on the record, to overrule any objection to page 222, lines 16-19 and 22-24. Signed by District Judge William M. Conley on 4/11/2016. (kwf)
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Filing 827
** TEXT ONLY ORDER **The parties joint stipulations (dkt. # #809 , #814 , #815 ) are all ACCEPTED. Signed by District Judge William M. Conley on 4/11/2016. (kwf)
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Filing 826
Minute Entry for proceedings held before District Judge William M. Conley: Fifth Day of Jury Trial held on 4/8/2016. Evidence entered, trial continues. [8:28] (Court Reporters CS, LS) (arw)
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Set/Reset Trial Date: 7th Day Jury Trial set for 4/12/2016 at 8:00 AM. (arw)
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Filing 825
Joint Stipulation for Admission of Summary of Exhibit 2098 (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 824
Brief in Support of #823 Proposed Special Verdict and Revisions to Jury Instructions Regarding Damages by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - ABA Model Jury Instructions) (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 823
Proposed Special Verdict - Damages (Proposed Revisions) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 822
Response to Proposed Damages Jury Instructions (Proposed Revisions) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 821
Joint Stipulation to Summarize Deposition Testimony of Ravi Raju and Iyappan Rathina (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 820
ORDER re: #817 Response to Narrative Deposition Summary. Signed by District Judge William M. Conley on 4/10/16. (bgw)
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Filing 819
ORDER re: Rulings on #745 and #813 Objections to Deposition Designations of Narasimhan Srinivasan and Natarajan Chandrasekaran. Signed by District Judge William M. Conley on 4/10/16. (bgw) Modified on 4/11/2016. (kwf)
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Filing 818
Deposition Designations. Defendants' Response to #813 Epic's Further Amended Deposition Designations of Narasimhan Srinivasan by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 817
Response to Narrative Deposition Summary of Ravi Raju and Iyappan Rathina. (Sealed Document) (Richmond, Rick)
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Filing 816
Contested Exhibits. Joint Request for the Court to Rule on the Disputed Redactions to Exhibits 94, 95, 96, 97 and 555 by Plaintiff Epic Systems Corporation. (Sealed Document) (Attachments: #1 Exhibit A - Epic's Proposed Redactions, #2 Exhibit B - TCS's Proposed Redactions) (Richmond, Rick) Modified on 4/11/2016: Added exhibit descriptions. (lak)
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Filing 815
Joint Stipulation to Summarize Deposition Testimony of Suraj Kartha, Arulbigju Kaspar, and Brad Kowalski (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Defendants' response to plaintiff's motion in limine to exclude exhibits and testimony related to the supplemental report of TCS's expert Erik Laykin (dkt. #810 ) is due by 12:00 p.m. on April 11, 2016. (bgw) Modified on 4/11/2016. (kwf)
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Filing 814
Joint Stipulation for Submission of Transcription of Curtis Bajak Notes (Sealed Document) by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 456A - Transcription of Handwritten Note (Redacted by Agreement), #2 Exhibit 457A - Transcription of Handwritten Note (Redacted by Agreement), #3 Exhibit 470 - Transcription of Handwritten Note) (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 813
Amended Deposition Designations of Narasimhan Srinivasan by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 812
Redaction to #811 Brief in Support of Motion in Limine to Exclude Exhibits and Testimony Related to the Supplemental Report of TCS's Expert Erik Laykin by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 811
Brief in Support of #810 Motion in Limine to Exclude Exhibits and Testimony Related to the Supplemental Report of TCS's Expert Erik Laykin by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 810
Motion in Limine to Exclude Exhibits and Testimony Related to the Supplemental Report of TCS's Expert Erik Laykin by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/11/2016. (lak)
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Filing 809
Joint Stipulation to Summarize Deposition Testimony of Nazia Khader, Venkatakrishnan Narasimhan, Deepa Pandurangan, Bharathi Ponnambalan, and Indana Susmita (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 808
ORDER re: Ruling on #745 Deposition Designations as to Curt Bajak. Signed by District Judge William M. Conley on 4/8/2016. (jls)
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Filing 807
ORDER re: Ruling on #777 Deposition Designations as to Vijaya Badipatla and Madhusudana Bandarapu. Signed by District Judge William M. Conley on 4/8/2016. (kwf)
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Filing 806
Minute Entry for proceedings held before District Judge William M. Conley: Fourth Day of Jury Trial held on 4/7/2016. Evidence entered, trial continues. [8:18] (Court Reporters CS, LS) (arw)
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Set/Reset Trial Date: 6th Day Jury Trial set for 4/11/2016 at 08:30 AM. (voc)
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Filing 805
Rule 26(a)(3) Pretrial Disclosures (Expert Witness Disclosure) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/8/2016. (lak)
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Filing 804
Errata Sheet to Deposition of Priscilla Kingston. (Sealed Document) (Neider, Barbara) Modified on 4/8/2016: Corrected docketing event. (lak)
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Filing 803
ORDER re: Ruling on #745 Deposition Designations as to Ajay Krishnaswamy. Signed by District Judge William M. Conley on 4/7/2016. (jls)
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Filing 802
ORDER re: Ruling on #745 Deposition Designations as to Jason Cline. Signed by District Judge William M. Conley on 4/7/2016. (kwf)
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Filing 801
ORDER re: Ruling on #733 and #767 Deposition Designations as to Ramareddy Baddam and Madhavi Mukherji. Signed by District Judge William M. Conley on 4/7/2016. (kwf)
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Filing 800
ORDER re: Ruling on #554 and #777 Deposition Designations as to Venugopal Reddy. Signed by District Judge William M. Conley on 4/7/2016. (kwf)
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Filing 799
ORDER re: Ruling on #767 Deposition Designations as to Srikanth Telkapalli. Signed by District Judge William M. Conley on 4/7/2016. (kwf)
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Filing 798
Minute Entry for proceedings held before District Judge William M. Conley: Third Day of Jury Trial held on 4/6/2016. Evidence entered, trial continues. [8:30] (Court Reporters CS, LS) (arw)
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Set/Reset Trial Date: 5th Day Jury Trial set for 4/8/2016 at 8:30 AM. (arw)
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Filing 797
Deposition of Erik Laykin taken on April 2, 2016. (Sealed Document) (Richmond, Rick)
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Filing 796
ORDER re: Ruling on #767 Deposition Designations as to Nazia Khader, Sankari Gunasekaran, Priscilla Kingston, Mukesh Kumar, and Vikran Vadamalai. Signed by District Judge William M. Conley on 4/6/2016. (kwf)
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Filing 795
Minute Entry for proceedings held before District Judge William M. Conley: Second Day of Jury Trial held on 4/5/2016. Evidence entered, trial continues. [7:33] (Court Reporters CS, LS) (arw)
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Set/Reset Trial Date: 4th Day Jury Trial set for 4/7/2016 at 8:30 AM. (arw)
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Filing 794
Minute Entry for proceedings held before District Judge William M. Conley: Jury Selection and First Day of Trial held on 4/4/2016. Evidence entered, trial continues. [6:43] (Court Reporters CS, LS) (arw)
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Filing 793
ORDER re: Ruling on #733 , #767 , and #792 Deposition Designations as to Santosh Mohanty, Mahendra Pandian, and Deepa Pandurangan. Signed by District Judge William M. Conley on 4/5/2016. (kwf)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Status Conference held on 4/3/2016. [1:05] (Court Reporter LS.) (kwf)
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Set/Reset Trial Date: 3rd Day Jury Trial set for 4/6/2016 at 8:30 AM. (arw)
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Filing 792
Corrected Deposition Designations for Santosh Mohanty by Plaintiff Epic Systems Corporation. (Saros, Nick)
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Filing 791
Deposition Designations (Request to Temporarily Withhold Review of Deposition Designations of Santosh Mohanty) by Plaintiff Epic Systems Corporation. (Saros, Nick)
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Filing 790
ORDER re: Ruling on #767 Deposition Designations as to Paul Amalraj. Signed by District Judge William M. Conley on 4/4/2016. (kwf)
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Filing 789
Transcript of Telephonic Status Conference, held 4/3/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 788
Transcript of Telephonic Status Conference, held 4/1/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Set/Reset Trial Date: 2nd Day Jury Trial set for 4/5/2016 at 8:30 AM. (arw)
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Filing 787
Deposition Designations in Response to Epic's Fifth Set of Amended Deposition Designations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 786
ORDER: GRANTING IN PART AND DENYING IN PART #779 Motion to present testimony from Stirling Martin and Carl Dvorak regarding the value of Epic's confidential and trade secret information by Plaintiff Epic Systems Corporation. Plaintiff's motion for clarification regarding rulings on objections to depositions designations of Duddukuru and Jones (dkt. #780 ) is GRANTED as to Duddukuru and GRANTED IN PART AND DENIED IN PART as to Jones. As for Duddukuru, the ruling is modified to sustain the objection from 179:21:-180:10. As for Jones, Epic may present deposition testimony simply directing the jury to the relevant portion of the Master Services Agreement, but Epic may not reinsert those lengthier portions struck by the court because they amount to reading from the agreement and asking the witness if he sees the relevant passage. The objection raised in defendants Tata Consultancy Services Limited and Tata America International Corporation's supplement (dkt. #778 ) is OVERRULED for the reasons provided on the record. Plaintiff's motion to file an opposition to defendants' supplement (dkt. #782 ) is GRANTED. Signed by District Judge William M. Conley on 4/3/2016. (bgw) Modified on 4/4/2016 (voc).
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Filing 785
ORDER re Rulings on #745 Deposition Designations of Bill McCarthy. Signed by District Judge William M. Conley on 4/3/2016. (bgw)
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Filing 784
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #779 Motion to Present Testimony from Stirling Martin and Carl Dvorak Regarding the Value of Epic's Confidential and Trade Secret Information filed by Epic Systems Corporation. (Neider, Barbara)
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Filing 783
Deposition Designations. Objections to Defendants' Response to Epic's Amended Deposition Designations of Witnesses Venu Medikonda, Commander Melmangalam Ramanathan Kumar, Curtis Bajak, David Jones, and Bill McCarthy by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 782
Opposition re: #778 Supplement. Opposition to Defendants' Supplement to Their Objections to Epic's Deposition Designations by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Richmond, Rick) Modified on 4/4/2016 (voc).
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Filing 781
Deposition Designations in Response to Epic's Fourth Set of Amended Deposition Designations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 780
Motion for Clarification re #771 Order re rulings on objections to deposition designations of Vishwa Prasad Duddukuru and David Jones by Plaintiff Epic Systems Corporation. Response due 4/11/2016. (Richmond, Rick) Modified on 4/4/2016 (voc).
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Filing 779
Motion to Present Testimony from Stirling Martin and Carl Dvorak Regarding the Value of Epic's Confidential and Trade Secret Information by Plaintiff Epic Systems Corporation. Response due 4/11/2016. (Richmond, Rick) Modified on 4/4/2016 (voc).
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Filing 778
Supplement to #641 Objections to Trial Exhibits filed by Tata Consultancy Services Limited, Tata America International Corporation, #774 Deposition Designations filed by Tata Consultancy Services Limited, Tata America International Corporation, #764 Deposition Designations filed by Tata Consultancy Services Limited, Tata America International Corporation, #751 Deposition Designations filed by Tata Consultancy Services Limited, Tata America International Corporation. (Neider, Barbara)
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Filing 777
Amended Deposition Designations as to Venugopal Reddy, Vijaya Badipatla, Ravi Raju, Venkatakrishnan Narasimhan, Bharathi Ponnambalam, Indana Susmita, Suraj Kartha, Arulbigju Kaspar, and Narasimhan Srinivasan. by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 776
ORDER on closing instructions. Signed by District Judge William M. Conley on 4/1/2016. (mfh)
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Filing 775
Notice by Plaintiff Epic Systems Corporation. (Jury Book Agreed Upon by Parties). (Tomaselli, Anthony)
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Filing 774
Deposition Designations (Response to Epic's Third Set of Amended Deposition Designations, re: Dkt #757) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 773
ORDER on Telephone Status Conference. Defendants' motion in limine to exclude testimony of experts Wes Rishel and Samuel S. Rubin (dkt. #690 ) is GRANTED IN PART, DENIED IN PART AND RESERVED IN PART as set forth on the record. Defendants' motion to supplement with respect to March 30, 2016, pretrial conference call (dkt. #746 ) is DENIED AS MOOT. The court will hold a telephonic conference on the parties' joint submission of remaining contested exhibits (dkt. #772 ) on Sunday, April 3, 2016, at 7:30 p.m. Plaintiff to establish call. Signed by District Judge William M. Conley on 4/1/2016. (kwf)
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Filing 772
Joint Stipulation for Remaining Contested Exhibits by Plaintiff Epic Systems Corporation. (Attachments: #1 Exhibit A - Contested Exhibits) (Richmond, Rick)
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Filing 771
ORDER re: Ruling on #745 Deposition Designations as to David Jones. Signed by District Judge William M. Conley on 4/1/2016. (kwf)
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Filing 770
Corrected Deposition Designations of Brad Kowalski by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 769
Counter Expert Report of Wes Rishel by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Set Status Conference: Telephone Status Conference set for 4/3/2016 at 7:30 PM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (kwf)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Status Conference held on 4/1/2016 [3:15] (Court Reporter LS.) (mfh)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Status Conference held on 3/30/2016 [:45] (Court Reporter LS.) (mfh)
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Filing 768
Objections to TCS's Requested Revisions to the Court's March 28, 2016 Jury Instructions, Verdict Form, and Voir Dire Questions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 767
Amended Deposition Designations of witnesses: Paul Amalraj, Santosh Mohanty, Mahendra Pandian, Nazia Khader, Sankari Gunasekaran, Priscilla Kingston, Mukesh Kumar, Vikram Vadamalai, Srikanth Telkapalli, Iyappan Rathina, and Ramareddy Baddam by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 766
Redaction to #754 Brief in Opposition, to TCS's Motion in Limine to Exclude Testimony Related to the Supplemental Expert Report of Wes Rishel and the Expert Report of Samuel S. Rubin by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 765
Witness List (Defendants' Order of Witnesses) by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 764
Deposition Designations (Response to Epic's Second Set of Amended Deposition Designations, Dkt. #745, 8 witnesses), by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 763
Redaction to #760 Objections to Proposed Jury Instructions. (Brief in Opposition to Epic's Proposed Revisions to the Court's Adverse Inference Jury Instruction) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 4/1/2016. (lak)
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Filing 762
** TEXT ONLY ORDER ** ORDER granting #758 Motion for Extension of Time. Signed by District Judge William M. Conley on 3/31/2016. (bgw)
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Filing 761
ORDER re Rulings on #733 Deposition Designations for Arun Agarawal, Vishwa Prasad Duddukuru and Anmol Gupta. Signed by District Judge William M. Conley on 3/31/2016. (bgw)
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Filing 760
Objections to #742 Proposed Jury Instructions (Brief in Opposition to Epic's Proposed Revisions to the Court's Adverse Inference Jury Instruction) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Neider, Barbara)
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Filing 759
Witness List (Plaintiff's Order of Witnesses) by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 4/1/2016. (lak)
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Filing 758
Joint Motion for Extension of Time to Submit Revised Materials for Jury Binder by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Tomaselli, Anthony)
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Filing 757
Amended Deposition Designations of Venu Medikonda and Melmangalam Ramanthan Kumar by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 756
Proposed Stipulation of Facts by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Neider, Barbara) Modified on 4/1/2016. (lak)
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Filing 755
Corrected Deposition Designations (Objections to TCS's counter-designations of Vishwa Prasad Duddukuru and Madhusudana Bandarapu) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 754
Brief in Opposition by Plaintiff Epic Systems Corporation re: #690 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation to Exclude Testimony Related to the Supplemental Expert Report of Wes Rishel and the Expert Report of Samuel S. Rubin (Sealed Document) (Richmond, Rick)
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Filing 753
Disregard. See #755 for Corrected Deposition Designations. Modified on 3/31/2016. (lak)
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Filing 752
Redaction to #750 Proposed Stipulation for Parties to Agree to Facts re: UserWeb Access (Sealed Document) by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Proposed Stipulation of Facts) (Richmond, Rick) Modified on 3/31/2016. (lak)
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Filing 751
Deposition Designations (Response to Epic's First Set of Amended Deposition Designations, Dkt. 733) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 750
Proposed Stipulation for Parties to Agree to Facts re: UserWeb Access (Sealed Document) by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Proposed Stipulation of Facts) (Richmond, Rick) Modified on 3/31/2016. (lak)
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Filing 749
Transcript of Telephonic Status Conference, held 3/30/2016 before Chief Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 748
Redaction to #746 Motion to Supplement with Respect to March 30, 2016 Pretrial Conference Call by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Attachments: #1 Exhibit A - TCS Supplemental Responses and Objections to Plaintiff's Feb. 25, 2016 Interrogatories) (Neider, Barbara) Modified on 3/30/2016: Corrected docketing event, termed motion, removed duplicate text. (lak)
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Filing 747
ORDER on Telephone Status Conference. Plaintiff Epic Systems Corporation's objections to two of TCS's witnesses is OVERRULED with respect to Vishwanathan Landeri, and RESERVED with respect to Dipankar Chakrabarty. Defendants Tata Consultancy Services Limited and Tata America International Corporation's response to plaintiff's amended deposition designations for six witnesses (dkt. #733 ) is due by 5:00 p.m., March 30, 2016. Defendants' response to plaintiff's amended deposition designations for eight witnesses (dkt. #745 ) is due by 5:00 p.m., March 31, 2016. Plaintiff's previously-served stipulation on the TCS TCOE witnesses is due by 5:00 p.m., March 30, 2016. Defendants' response to the proposed stipulation is due by 5:00 p.m., March 31, 2016. Both sides may submit revised materials for the jury binder by 5:00 p.m., March 31, 2016. Signed by District Judge William M. Conley on 3/30/2016. (kwf)
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Filing 746
Motion to Supplement with Respect to March 30, 2016 Pretrial Conference Call (Sealed Document) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Attachments: #1 Exhibit A - TCS Supplemental Responses and Objections to Plaintiff's Feb. 25, 2016 Interrogatories) (Neider, Barbara)
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Filing 745
Amended Deposition Designations (Bajak, Chandrasekaran, Cline, Jones, Kowalski, Krishnaswamy, McCarthy, Srinivasan) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 744
Corrected Witness List by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 743
Disregard. See #744 for Corrected Witness List. Modified on 3/30/2016. (lak)
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Filing 742
Proposed Revisions to the Adverse Inference Instruction by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/30/2016. (lak)
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Filing 741
Redaction to #739 Witness List (Opposition to Epic's Statement Regarding TCS Witnesses) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/30/2016. (lak)
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Filing 740
Declaration of Philip D. Robben in Support of re: #739 Witness List (Opposition to Epic's Statement Regarding TCS Witnesses), (Attachments: #1 Exhibit A - Email from TCS to Epic re: Scheduling Inspections) (Robben, Philip) Modified on 3/30/2016. (lak)
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Filing 739
Witness List (Opposition to Epic's Statement Regarding TCS Witnesses) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/30/2016. (lak)
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Filing 738
Brief in Support re: #735 Requested Revisions to the Court's March 28, 2016 Closing Instructions, #736 Requested Revisions to the Court's March 28, 2016 Verdict Form by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/30/2016. (lak)
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Filing 737
Revisions to Proposed Voir Dire and Orientation Remarks by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/30/2016. (lak)
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Filing 736
Requested Revisions to the Court's March 28, 2016 Verdict Form by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/30/2016. (lak)
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Filing 735
Requested Revisions to the Court's March 28, 2016 Closing Instructions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/30/2016. (lak)
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Filing 734
Revised Witness List by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/30/2016. (lak)
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Filing 733
Amended Deposition Designations by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 732
Redaction to #730 Declaration of Rick Richmond In Support Of Epic's Statement Regarding TCS Witnesses Not Disclosed During Discovery by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Epic's Sixth Set of Interrogatories, #2 Exhibit 2 - TCS Responses and Objections to Epic's Sixth Set of Interrogatories) (Richmond, Rick) Modified on 3/29/2016. (lak)
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Filing 731
Redaction to #729 Witness List (Epic's Statement Regarding TCS Witnesses Not Disclosed During Discovery) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 730
Declaration of Rick Richmond In Support Of Epic's Statement Regarding TCS Witnesses Not Disclosed During Discovery by Plaintiff Epic Systems Corporation, (Sealed Document) (Attachments: #1 Exhibit 1 - Epic's Sixth Set of Interrogatories, #2 Exhibit 2 - TCS Responses and Objections to Epic's Sixth Set of Interrogatories) (Richmond, Rick) Modified on 3/29/2016. (lak)
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Filing 729
Witness List (Epic's Statement Regarding TCS Witnesses Not Disclosed During Discovery) by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 728
OPINION AND ORDER. The January 11, 2016 Order to Show Cause #391 is deemed satisfied and discharged. Stroz Friedburg LLC's motion #496 to expunge or amend the order is granted in part and denied in part, consistent with this opinion. Signed by District Judge William M. Conley on 3/28/2016. (arw)
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Filing 727
Transcript of Telephonic Status Conference, held 3/25/2016 before District Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 726
Transcript of Final Hearing, held 3/24/2016 before District Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Set Briefing Deadlines re: #690 Motion in Limine to Exclude Testimony Related to the Supplemental Expert Report of Wes Rishel and the Expert Report of Samuel S. Rubin. Response due 3/30/2016. See #719 ORDER on Final Pretrial Conference. (arw)
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Filing 725
Redaction to #724 Expert Report, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Bersin CV, #2 Exhibit B - Expert Testimony and Disclosures) (Robben, Philip)
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Filing 724
Expert Report of Brent K. Bersin regarding damages by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Sealed Document) (Attachments: #1 Exhibit A - Bersin CV, #2 Exhibit B - Expert Testimony and Disclosures) (Robben, Philip)
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Filing 723
Redaction to #722 Expert Report by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Nadkarni Report) (Robben, Philip)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Status Conference held on 3/25/2016 [:30] (Court Reporter LS.) (mfh)
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Filing 722
Expert Report of Prakash Nadkarni by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (MacGregor, Alison) Modified on 3/25/2016: Appendix A and B are attached. (lak)
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Filing 721
Expert Witness Disclosures by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 720
Expert Witness Disclosures by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 719
ORDER on Final Pretrial Conference; setting briefing on #690 Motion in Limine, denying #543 Motion in Limine, denying as moot #561 Motion in Limine, denying in part and reserving in part #590 Motion in Limine. Signed by District Judge William M. Conley on 03/24/2016. (mfh) Modified on 3/28/2016. (arw)
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Filing 717
Minute Entry for proceedings held before District Judge William M. Conley: Final Pretrial Conference held on 3/24/2016. Trial predicted to last 10 days. Fourteen jurors will be called forward, eight jurors will be impaneled. Telephone Status Conferences set for 3/25/2016, 3/30/2016 and 4/1/2016 at 11:00 AM before District Judge William M. Conley. Counsel for plaintiff responsible for setting up the call to chambers at (608) 264-5087. [3:35] (Court Reporter LS) (arw)Attention: In the event of a settlement of this matter over the weekend, counsel are advised to contact the Clerk of Court at (608) 287-4875 or the Chief Deputy Clerk at (608) 354-8004.
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Filing 716
Supplemental Expert Report of Wes Rishel by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/25/2016: Exhibits B, C and D are attached. (lak)
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Filing 715
Expert Report of Samuel S. Rubin by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/25/2016: Exhibits 1 - 7 are attached. (lak)
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Filing 714
Redaction to #711 Deposition Designations (Brief In Support of Objections to TCS's Deposition Designations) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Set Deadlines and Hearings: Telephone Status Conferences set for 3/25/2016, 3/30/2016 and 4/1/2016 at 11:00 AM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (arw)
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Filing 713
Redaction to #712 Deposition Designations (Brief in Support of Objections to Epic's Deposition Designations) by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Progress Chart for Deposition Designations, #2 Exhibit B - Witness Objection and Counter-Designation Chart (Part 1), #3 Exhibit B - Witness Objection and Counter-Designation Chart (Part 2), #4 Exhibit B - Witness Objection and Counter-Designation Chart (Part 3)) (Robben, Philip)
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Filing 712
Deposition Designations (Brief in Support of Objections to Epic's Deposition Designations) by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Sealed Document) (Attachments: #1 Exhibit A - Progress Chart for Deposition Designations, #2 Exhibit B - Witness Objection and Counter-Designation Chart (Part 1), #3 Exhibit B - Witness Objection and Counter-Designation Chart (Part 2), #4 Exhibit B - Witness Objection and Counter-Designation Chart (Part 3)) (Robben, Philip)
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Filing 711
Deposition Designations (Brief In Support of Objections to TCS's Deposition Designations) by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 710
Deposition of Kela Feldman taken on December 2, 2015. (Sealed Document) (Richmond, Rick)
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Filing 709
ORDER granting plaintiff's #521 Motion for Sanctions as set forth in the order; denying defendants' #604 Motion for Sanctions Signed by District Judge William M. Conley on 03/23/2016. (mfh)
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Filing 708
Corrected Deposition Designations Regarding Anuj Karla by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 707
Objection to Rule 26(a)(3) Designations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 706
Objection to Rule 26(a)(3) Designations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 705
Notice by Plaintiff Epic Systems Corporation Regarding Bottled Water During Trial. (Boor, Anita)
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Filing 704
Redaction to #699 Supplemental Expert Report of Erik Laykin dated March 21, 2016 by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Laykin CV, #2 Exhibit B - Materials Relied Upon, #3 Exhibit C - Eligible Hospital Tables, #4 Exhibit D - Evolve Suite White Paper, #5 Exhibit E - Epic Initial Development, #6 Exhibit F - Med Mantra Development, #7 Exhibit H - Epic and Med Mantra Screenshots, #8 Exhibit I - Appendex A: Glossaries of Terms) (Neider, Barbara)
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Filing 703
ORDER granting #532 Motion for Leave to File and Motion for Partial Summary Judgment on defendants' unclean hands affirmative defense; denying #511 Motion in Limine; denying #540 Motion in Limine; denying in part and reversing in part #543 Motion in Limine; denying #556 Motion in Limine; granting in part, denying in part and reversing in part #561 Motion in Limine; denying #564 Motion in Limine; granting in part and denying in part #567 Motion in Limine; denying #571 Motion in Limine; denying #573 Motion in Limine; granting #575 Motion in Limine; granting #577 Motion in Limine; denying #579 Motion in Limine; denying as moot #581 Motion in Limine; granting in part,denying in part and reversing in part #590 Motion in Limine. Signed by District Judge William M. Conley on 3/23/2016. (jls)
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Filing 702
Supplemental Exhibit List by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 701
Redaction to #700 Expert Report by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Attachment 1 - Slipsheet, #2 Attachment 2 - Slipsheet, #3 Exhibit 1 - Slipsheet, #4 Exhibit 2 - Slipsheet) (Robben, Philip) Modified on 3/23/2016. (lak)
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Filing 700
Supplemental Expert Report of Brent K. Bersin regarding damages by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited (Sealed Document) (Attachments: #1 Attachment 1 - Bersin CV, #2 Attachment 2 - Documents Reviewed and Considered, #3 Exhibit A - Epic Revenue, #4 Exhibit B - TCS Revenues from Med Mantra) (Robben, Philip)
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Filing 699
Supplemental Expert Report of Erik Laykin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited (Sealed Document) (Attachments: #1 Appendix A, #2 Exhibit A - Laykin CV, #3 Exhibit B - Materials Relied Upon, #4 Exhibit C - Eligible Hospital Tables, #5 Exhibit D - Evolve Suite White Paper, #6 Exhibit E - Epic Initial Development, #7 Exhibit F - Med Mantra Development, #8 Exhibit H - Epic and Med Mantra Screenshots) (Robben, Philip)
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Filing 698
Disregard. See #699 . (Sealed Document) Modified on 3/22/2016. (lak)
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Filing 697
Disregard. See #700 . (Sealed Document) Modified on 3/22/2016. (lak)
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Filing 696
Notice of Appearance filed by Anita Marie Boor for Plaintiff Epic Systems Corporation. (Boor, Anita)
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Filing 695
Deposition Designations (Objections to TCS's Counter-Designations) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 694
Redaction to #693 Declaration of Philip D. Robben by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - September 24, 2015 Email Between Melissa Byroade, Counsel for TCS, and Annamarie Van Hoesen, Counsel for Epic, #4 Exhibit D - November 24, 2015 Email Between Melissa Byroade, Counsel for TCS, and Julie Shepard, Counsel for Epic) (Robben, Philip) Modified on 3/21/2016. (lak)
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Filing 693
Declaration of Philip D. Robben in Support re: #690 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit A - Supplemental Expert Report of Wes Rishel (With Exhibits) (Has not been filed separately.), #2 Exhibit B - Expert Report of Samuel S. Rubin (With Exhibits) (Has not been filed separately.), #3 Exhibit C - September 24, 2015 Email Between Melissa Byroade, Counsel for TCS, and Annamarie Van Hoesen, Counsel for Epic, #4 Exhibit D - November 24, 2015 Email Between Melissa Byroade, Counsel for TCS, and Julie Shepard, Counsel for Epic) (Robben, Philip) Modified on 3/21/2016. (lak)
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Filing 692
Redaction to #691 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/21/2016. (lak)
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Filing 691
Brief in Support of #690 Motion in Limine to Exclude Testimony Related to the Supplemental Expert Report of Wes Rishel and the Expert Report of Samuel S. Rubin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/21/2016. (lak)
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Filing 690
Motion in Limine to Exclude Testimony Related to the Supplemental Expert Report of Wes Rishel and the Expert Report of Samuel S. Rubin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/21/2016. (lak)
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Filing 689
Deposition Designations (Objections to Epic's Deposition Counter-Designations) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 688
Redaction to #628 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/18/2016. (lak)
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Filing 687
Supplemental Deposition Designations by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 686
Redaction to #675 Declaration of Samuel S. Rubin by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 685
Redaction to #673 Declaration of Nick Saros by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - 3/7/2016 to 3/8/2016 Email correspondence between Philip Robben and Nick Saros, #2 Exhibit 2 - 11/20/2015 to 11/24/2015 Email correspondence between Melissa Byroade and Julie Shepard, #3 Exhibit 3 - 2/26/2016 email correspondence from Philip Robben to Nick Saros, #4 Exhibit 4 - Slipsheet, #5 Exhibit 5 - 3/3/2016 to 3/8/2016 Email correspondence between Alison MacGregor and Julie Shepard, #6 Exhibit 6 - Slipsheet) (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 684
Redaction to #677 Declaration of Julie Shepard by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E - Slipsheet, #6 Exhibit F - Slipsheet, #7 Exhibit G - Slipsheet, #8 Exhibit H - Slipsheet, #9 Exhibit I - Slipsheet, #10 Exhibit J - Slipsheet, #11 Exhibit K - Slipsheet, #12 Exhibit L - Slipsheet, #13 Exhibit M - Slipsheet, #14 Exhibit N - Slipsheet) (Shepard, Julie) Modified on 3/17/2016. (lak)
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Filing 683
Redaction to #670 Brief in Opposition by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/17/2016. (lak)
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Filing 682
Redaction to #639 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 681
Redaction to #633 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 680
Redaction to #638 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 679
Redaction to #637 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 678
Redaction to #630 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/17/2016. (lak)
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Filing 677
Declaration of Julie Shepard filed by Plaintiff Epic Systems Corporation in Support of Epic's Opposition re: #604 Motion for Sanctions, (Sealed Document) (Attachments: #1 Exhibit A - 11/30/2015 Plaintiff's Request for Inspection (Forensic Analysis), #2 Exhibit B - Rubin statements chart, #3 Exhibit C - 12/22/2015 Email re Kiosk Log, #4 Exhibit D - Deposition Exhibit 713, #5 Exhibit E - Deposition Exhibit 732, #6 Exhibit F - Document bates stamped TCS00302743 through TCS00302743_002, #7 Exhibit G - Deposition Exhibit 736, #8 Exhibit H - Deposition Exhibit 735, #9 Exhibit I - Deposition Exhibit 710, #10 Exhibit J - Deposition Exhibit 711, #11 Exhibit K - Deposition Exhibit 712, #12 Exhibit L - Deposition Exhibit 729, #13 Exhibit M - Deposition Exhibit 714, #14 Exhibit N - Deposition Exhibit 737) (Shepard, Julie)
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Filing 676
Disregard. Duplicate of #648 . Modified on 3/16/2016. (lak)
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Filing 675
Declaration of Samuel S. Rubin filed by Plaintiff Epic Systems Corporation in Support of Epic's Opposition re: #604 Motion for Sanctions. (Sealed Document) (Richmond, Rick)
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Filing 674
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #581 Motion in Limine filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 673
Declaration of Nick Saros filed by Plaintiff Epic Systems Corporation in Support of Epic's Oppositions re: #556 Motion in Limine, #511 Motion in Limine, #540 Motion in Limine, #564 Motion in Limine, #561 Motion in Limine, #543 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit 1 - 3/7/2016 to 3/8/2016 Email correspondence between Philip Robben and Nick Saros, #2 Exhibit 2 - 11/20/2015 to 11/24/2015 Email correspondence between Melissa Byroade and Julie Shepard, #3 Exhibit 3 - 2/26/2016 email correspondence from Philip Robben to Nick Saros, #4 Exhibit 4 - 3/14/2016 - Epic's Supplemental Expert Report of Thomas W. Britven, #5 Exhibit 5 - 3/3/2016 to 3/8/2016 Email correspondence between Alison MacGregor and Julie Shepard, #6 Exhibit 6 - Document bates stamped EPIC1698403-EPIC1698407.) (Saros, Nick)
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Filing 672
Disregard. See #677 . (Sealed Document) Modified on 3/16/2016. (lak)
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Filing 671
Disregard. See #675 . (Sealed Document) (Richmond, Rick) Modified on 3/16/2016. (lak)
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Filing 670
Brief in Opposition by Plaintiff Epic Systems Corporation re: #604 Motion for Sanctions, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Richmond, Rick)
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Filing 669
Declaration of Rick Richmond re: #668 Objection to Provisional Witness List, (Attachments: #1 Exhibit A - Linked In Page of Dipankar Chakraborty, #2 Exhibit B - 2/18/2016 Email to TCS re: Venugopal Reddy Deposition) (Richmond, Rick) Modified on 3/16/2016. (lak)
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Filing 668
Objection to Provisional Witness List, by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/16/2016. (lak)
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Filing 667
Deposition Designations of TCS objected to and counter-designated by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 666
Redaction to #665 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 665
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #579 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 664
Redaction to #663 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 663
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #577 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 662
Redaction to #661 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 661
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #567 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 660
Redaction to #659 Declaration of Erik Laykin by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Laykin CV, #2 Exhibit B - Slipsheet, #3 Exhibit C - Order denying motion exclude Laykin) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 659
Declaration of Erik Laykin filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #590 Motion in Limine (Sealed Document) (Attachments: #1 Exhibit A - Laykin CV, #2 Exhibit B - Symantec motion to exclude Laykin, #3 Exhibit C - Order denying motion exclude Laykin) (Robben, Philip)
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Filing 658
Deposition Designations of Epic Systems Corporation objected to and counter-designated by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 657
Redaction to #656 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 656
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #590 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 655
Objections to Trial Exhibits by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 654
Disregard. See #673 . (Sealed Document) Modified on 3/16/2016. (lak)
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Filing 653
Redaction to #652 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 652
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #532 Motion for Leave to File, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 651
Redaction to #650 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 650
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #573 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 649
Redaction to #647 Declaration of Philip D. Robben by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 648
Redaction to #674 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 647
Declaration of Philip D. Robben in Opposition re: #581 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit A - Exhibit 1099, #2 Exhibit B - Exhibit 1095, #3 Exhibit C - Exhibit 1087) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 646
Disregard. See #674 . (Sealed Document) Modified on 3/16/2016. (lak)
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Filing 645
Redaction to #644 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 644
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #575 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 643
Redaction to #642 Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 642
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #571 Motion in Limine, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 3/16/2016. (lak)
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Filing 641
Objections to Trial Exhibits of Epic Systems Corporation by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/16/2016. (lak)
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Filing 640
Proposed Supplemental Voir Dire by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 3/16/2016. (lak) (Additional attachment(s) added on 3/16/2016: #1 Exhibit A - Sampling of News Articles) (lak).
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Filing 639
Brief in Opposition by Plaintiff Epic Systems Corporation re: #540 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 638
Brief in Opposition by Plaintiff Epic Systems Corporation re: #561 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 637
Brief in Opposition by Plaintiff Epic Systems Corporation re: #556 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 636
Response to #587 Proposed Voir Dire of Epic Systems Corporation by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Vergeront, Meg) Modified on 3/16/2016: Linked to the document. (lak)
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Filing 635
Response to #588 , #589 Proposed Special Verdict of Epic Systems Corporation by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Vergeront, Meg) Modified on 3/16/2016: Linked to the documents. (lak)
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Filing 634
Response to Proposed Liability and Damages Jury Instructions of Epic Systems Corporation by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Vergeront, Meg) Modified on 3/16/2016. (lak)
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Filing 633
Brief in Opposition by Plaintiff Epic Systems Corporation re: #564 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 632
Objections to #547 Proposed Voir Dire by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 631
Objections to #552 Proposed Special Verdict, #551 Proposed Jury Instructions by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 630
Brief in Opposition by Plaintiff Epic Systems Corporation re: #511 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 629
Declaration of Philip D. Robben in Support of Defendants' Opposition to Epic's Request for a Missing Witness Instruction. (Neider, Barbara)
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Filing 628
Brief in Opposition by Plaintiff Epic Systems Corporation re: #543 Motion in Limine, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 627
Deposition of Anuj Kalra taken on January 20, 2016. (Sealed Document) (Robben, Philip)
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Filing 626
Deposition of Kaylan Dahnireddy taken on January 18, 2016. (Sealed Document) (Robben, Philip)
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Filing 625
Deposition of Karun Biyani taken on January 18, 2016. (Sealed Document) (Robben, Philip)
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Filing 624
** TEXT ONLY ORDER **ORDER granting #623 Motion to Admit Talat Ansari Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 3/14/2016. (lak)
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Filing 623
Motion to Admit Talat Ansari Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt number 0758-1766208.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Ansari, Talat)
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Filing 622
Redaction to #621 Declaration of Philip D. Robben by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - SlipSheet, #3 Exhibit C - SlipSheet, #4 Exhibit D - SlipSheet) (Robben, Philip) Modified on 3/14/2016. (lak)
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Filing 621
Declaration of Philip D. Robben in Support of Defendants' Memorandum of Law in Opposition filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #521 Motion for Sanctions, (Sealed Document) (Attachments: #1 Exhibit A - Exhibit 397, #2 Exhibit B - 2015-10-14 Letter to M. Byroade, #3 Exhibit C - TCS Supplemental Responses to First Set of Interrogatories, #4 Exhibit D - March 2016 Email Correspondence re: Inspections) (Robben, Philip) Modified on 3/14/2016: Removed duplicate text. (lak)
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Filing 620
Redaction to #619 Declaration of Ajit Menon by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - SlipSheet) (Robben, Philip)
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Filing 619
Declaration of Ajit Menon filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #521 Motion for Sanctions, (Sealed Document) (Attachments: #1 Exhibit A - Menon Chart re: Downloads, #2 Exhibit B - Menon Correspondence with Stroz) (Robben, Philip) Modified on 3/14/2016: Removed duplicate text. (lak)
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Filing 618
Redaction to #617 Declaration of Erik Laykin by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Laykin Bio, #2 Exhibit B - SlipSheet, #3 Exhibit C - SlipSheet, #4 Exhibit D - SlipSheet) (Robben, Philip)
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Filing 617
Declaration of Erik Laykin filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #521 Motion for Sanctions , (Sealed Document) (Attachments: #1 Exhibit A - Laykin Bio, #2 Exhibit B - Release Notes- (Part 1), #3 Exhibit B - Release Notes- (Part 2), #4 Exhibit B - Release Notes- (Part 3), #5 Exhibit B - Release Notes- (Part 4), #6 Exhibit B - Release Notes- (Part 5), #7 Exhibit B - Release Notes- (Part 6), #8 Exhibit C - Traceability Matrix, #9 Exhibit D - Test Summary Reports) (Robben, Philip) Modified on 3/14/2016: Removed duplicate text. (lak)
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Filing 616
Redaction to #615 Brief in Opposition to Plaintiff's Motion for Sanctions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 615
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #521 Motion for Sanctions filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 614
Deposition of Madhusudana Bandarapu taken on March 4, 2016. (Sealed Document) (Shepard, Julie)
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Filing 613
Deposition of Sumana Sravanthi taken on March 3, 2016. (Sealed Document) (Shepard, Julie)
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Filing 612
Deposition of Natarajan Chandrasekaran taken on March 2, 2016. (Sealed Document) (Shepard, Julie)
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Filing 611
Notice of Appearance filed by Alina Cristina Mejer for Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Mejer, Alina)
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Filing 610
Notice of Appearance filed by Kristina M Allen for Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Allen, Kristina)
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Set Briefing Deadlines as to #604 Renewed Motion for Sanctions. Response due 3/15/2016. No reply. (kwf/bgw)
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Filing 609
Exhibits to #607 Declaration filed by Tata Consultancy Services Limited, Tata America International Corporation. Exhibit F - Ajit Menon Interview Volume 1. (Ex Parte Document) (Attachments: #1 Exhibit G - Ajit Menon Interview, Volume 2) (Robben, Philip) Modified on 3/8/2016. (lak)
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Filing 608
Redaction to #607 Declaration of August Horvath by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E - Slipsheet, #6 Exhibit F - Slipsheet, #7 Exhibit G - Slipsheet, #8 Exhibit H - Slipsheet, #9 Exhibit I - Slipsheet, #10 Exhibit J - Slipsheet, #11 Exhibit K - Slipsheet, #12 Exhibit L - Slipsheet) (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 607
Declaration of August Horvath in Support of Defendants' Renewed Motion for Sanctions filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #604 Renewed Motion for Sanctions, (Sealed Document) (Attachments: #1 Exhibit A - Select pages from Exhibit 1114, #2 Exhibit B - Exhibit 1120, #3 Exhibit C - Exhibit 1128, #4 Exhibit D - Exhibit 1122, #5 Exhibit E - Exhibit 1121, #6 Exhibit F - Slipsheet. See #609 for the document., #7 Exhibit G - Slipsheet. See #609 for the document., #8 Exhibit H - Exhibit 1129, #9 Exhibit I - Exhibit 1123, #10 Exhibit J - Exhibit 1118, #11 Exhibit K - Exhibit 1116, #12 Exhibit L - Exhibit 1115) (Robben, Philip) Modified on 3/8/2016. (lak)
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Filing 606
Redaction to #605 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 605
Brief in Support of #604 Renewed Motion for Sanctions by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 604
Renewed Motion for Sanctions by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 603
Deposition of Rick Richmond taken on 02/05/16. (Sealed Document) (Robben, Philip)
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Filing 602
Deposition of Samuel Rubin taken on 02/05/16. (Sealed Document) (Robben, Philip)
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Filing 601
Redaction to #591 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 600
Redaction to #585 Declaration of Rick Richmond by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit 1 - Slipsheet, #2 Exhibit 2 - Slipsheet, #3 Exhibit 3 - Slipsheet, #4 Exhibit 4 - 3/3/2016 Email correspondence between Alison MacGregor and Julie Shepard) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 599
Redaction to #582 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 598
Redaction to #580 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 597
Redaction to #578 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 596
Redaction to #576 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 595
Redaction to #574 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 594
Redaction to #572 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 593
Redaction to #568 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 592
Exhibit List by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 591
Brief in Support of #590 Motion in Limine -Daubert Motion To Exclude Certain Opinions Of TCS's Expert Erik Layki) by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 590
Motion in Limine -Daubert Motion To Exclude Certain Opinions Of TCS's Expert Erik Laykin by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 589
Proposed Special Verdict - Damages by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 588
Proposed Special Verdict - Liability by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 587
Proposed Voir Dire by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 586
Deposition Designations by Plaintiff Epic Systems Corporation. (Attachments: #1 Exhibit A - Index And Page Lines Of Epic's Deposition Designations) (Richmond, Rick)
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Filing 585
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation In Support Of Epic's Motions In Limine re: #571 Motion in Limine, #579 Motion in Limine, #575 Motion in Limine, #567 Motion in Limine, #581 Motion in Limine, #573 Motion in Limine, #577 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit 1 - 2/25/2016 Defendants' Supplemental Responses and Objections to Plaintiff's First Set of Interrogatories, #2 Exhibit 2 - Deposition Exhibit 1052, #3 Exhibit 3 - 2/2/2016 Defendants' Responses and Objections to Plaintiff's Sixth Set of Interrogatories, #4 Exhibit 4 - 3/3/2016 Email correspondence between Alison MacGregor and Julie Shepard) (Richmond, Rick)
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Filing 584
Rule 26(a)(3) Pretrial Disclosures by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - Rule 26(a)(3) Statement for Wes Rishel, #2 Exhibit B - Rule 26(a)(3) Statement for Thomas Britven, #3 Exhibit C - Rule 26(a)(3) Statement for Samuel Rubin, #4 Exhibit D - Rule 26(a)(3) statement for Carl Dvorak, #5 Exhibit E - Rule 26(a)(3) Statement for Stirling Martin) (Richmond, Rick)
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Filing 583
Proposed Jury Instructions - Liability and Damages by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 582
Brief in Support of #581 Motion in Limine No. 7 to Preclude Evidence And Argument Of The Matters Raised By TCS In Its "Unclean Hands" Defense by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 581
Motion in Limine No. 7 to Preclude Evidence And Argument Of The Matters Raised By TCS In Its "Unclean Hands" Defense by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 580
Brief in Support of #579 Motion in Limine No. 6 to Preclude Evidence And Argument Re Philippe Guionnet's Allegations Relating To Topics Other Than Epic by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 579
Motion in Limine No. 6 to Preclude Evidence And Argument Re Philippe Guionnet's Allegations Relating To Topics Other Than Epic by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 578
Brief in Support of #577 Motion in Limine No. 5 to Preclude Evidence And Argument That TCS's Med Mantra-Based Software Was Not Improved Using Epic's Confidential Information In The EHR Products Epic Was Never Allowed To Inspect by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 577
Motion in Limine No. 5 to Preclude Evidence And Argument That TCS's Med Mantra-Based Software Was Not Improved Using Epic's Confidential Information In The EHR Products Epic Was Never Allowed To Inspect by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 576
Brief in Support of #575 Motion in Limine No. 4 to Preclude Evidence And Argument Regarding Epic's Alleged Contractual Obligation To Provide TCS Access To Userweb by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 575
Motion in Limine No. 4 to Preclude Evidence And Argument Regarding Epic's Alleged Contractual Obligation To Provide TCS Access To Userweb by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 574
Brief in Support of #573 Motion in Limine No. 3 to Preclude Evidence And Argument That TCS Used Epic's Confidential Information Only For Testing Services by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 573
Motion in Limine No. 3 to Preclude Evidence And Argument That TCS Used Epic's Confidential Information Only For Testing Services by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 572
Brief in Support of #571 Motion in Limine No. 2 To Preclude Evidence And Argument That Only A Limited Number Of Individuals Or Testing Teams Accessed Epic's Userweb by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 571
Motion in Limine No. 2 to Preclude Evidence And Argument That Only A Limited Number Of Individuals Or Testing Teams Accessed Epic's Userweb by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 570
Redaction to #569 Declaration of Philip D. Robben by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E - Slipsheet, #6 Exhibit F - Slipsheet) (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 569
Declaration of Philip D. Robben in support of defendants' motion in limine to exclude the "comparative analysis" document filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #564 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit A - Deposition Exhibit 97, #2 Exhibit B - Nick Saros's Declaration in Support of Epic's Motion for Expedited Discovery, dated November 6, 2014, #3 Exhibit C - Suresh Muthuswami's Declaration in Support of Epic's Motion for Expedited Discovery, dated November 30, 2015, #4 Exhibit D - Epic's Objections and Responses to TCS's Third Set of Interrogatories, dated February 2, 2016, #5 Exhibit E - Ajit Menon's Declaration in Support of Epic's Motion for Expedited Discovery, dated December 16, 2015, #6 Exhibit F - TCS's Responses and Objections to Plaintiff's First Set of Interrogatories, dated May 26, 2015) (Robben, Philip)
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Filing 568
Brief in Support of #567 Motion in Limine No. 1 to Preclude Evidence And Argument That TCS Could Have Created The Med Mantra-Epic Comparative Analysis From Publicly Available Information by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 567
Motion in Limine No. 1 to Preclude Evidence And Argument That TCS Could Have Created The Med Mantra-Epic Comparative Analysis From Publicly Available Information by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 3/7/2016. (lak)
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Filing 566
Redaction to #565 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 565
Brief in Support of #564 Motion in Limine to Exclude the "Comparative Analysis" Document by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 564
Motion in Limine to Exclude the Comparative Analysis by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 563
Declaration of Philip D. Robben in support of defendants' motion in limine to exclude any references to TCS's participation in outsourcing, its use of H1B visas, or it being a "foreign" company filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #561 Motion in Limine, (Attachments: #1 Exhibit A - Article dated 02/19/2016 and titled "The Fight Over Immigrant Workers Heads to Dairy Farms" from The Huffington Post, #2 Exhibit B - Article dated 02/08/2013 and titled "Offshoring Continues to Cost Wisconsin Among the Most Jobs in the Country", #3 Exhibit C - Article dated 02/18/16 and titled "Thousands protest 'anti-immigrant' legislation in Wisconsin" from CNNPolitics.com) (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 562
Brief in Support of #561 Motion in Limine to Exclude Any References to TCS's Participation in Outsourcing, Its Use of H1B Visas, or It Being a "Foreign" Company by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 561
Motion in Limine to Exclude Any References to TCS's Participation in Outsourcing, Its Use of H1B Visas, or It Being a "Foreign" Company by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 560
Redaction to #559 Declaration of Philip D. Robben by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - TCS's Second Set of Document Requests, dated June 12, 2015, #2 Exhibit B - TCS's Second Set of Interrogatories, dated June 12, 2015, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet) (Robben, Philip) Modified on 3/7/2016: Deleted duplicate text. (lak)
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Filing 559
Declaration of Philip D. Robben in support of defendants' motion in limine to exclude evidence and argument related to plaintiff's claim for damages filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #556 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit A - TCS's Second Set of Document Requests, dated June 12, 2015, #2 Exhibit B - TCS's Second Set of Interrogatories, dated June 12, 2015, #3 Exhibit C - Epic's Objections and Responses to TCS's Second Set of Document Requests, dated July 20, 2015, #4 Exhibit D - Epic's Supplemental Responses to TCS's Second Set of Document Requests, dated December 2, 2015) (Robben, Philip)
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Filing 558
Redaction to #557 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 557
Brief in Support of #556 Motion in Limine to Exclude Evidence and Argument Related to Plaintiff's Claims for Damages by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/7/2016: Deleted dupliate text. (lak)
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Filing 556
Motion in Limine to Exclude Evidence and Argument Related to Plaintiff's Claims for Damages by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 555
Witness List by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 554
Witness List and Deposition Designations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 553
Memorandum in Support of #552 Proposed Special Verdict, #551 Proposed Jury Instructions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 552
Proposed Special Verdict - Liability and Damages by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 551
Proposed Jury Instructions - Liability and Damages by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 550
Expert Witness Disclosures by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 549
Redaction to #548 Declaration of Melissa E. Byroade by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - August 18. 2015 letter Philippe Guionnet emailed to Rick Richmond and Natajaran Chandrasekaran, #2 Exhibit B - August 21, 2015 email Philippe Guionnet sent to Melissa Byroade, Philip Robben, Lee Brenner and Rick Richmond, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E- press release, dated June 13, 2013, from the Apollo Hospitals website, entitled "HIMSS Analytics Stage 6 Award") (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 548
Declaration of Melissa E. Byroade in support of defendants' motion in limine to exclude the deposition testimony of Philippe Guionnet and to preclude Mr. Guionnet from testifying at trial regarding the development of Med Mantra filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #543 Motion in Limine, (Sealed Document) (Attachments: #1 Exhibit A - August 18. 2015 letter Philippe Guionnet emailed to Rick Richmond and Natajaran Chandrasekaran, #2 Exhibit B - August 21, 2015 email Philippe Guionnet sent to Melissa Byroade, Philip Robben, Lee Brenner and Rick Richmond, #3 Exhibit C - Nick Saros's Declaration in Support of Epic's Motion for Expedited Discovery, dated November 6, 2014, #4 Exhibit D - Deposition Exhibit 97, #5 Exhibit E - Press Release, dated June 13, 2013, from the Apollo Hospitals website, entitled "HIMSS Analytics Stage 6 Award") (Robben, Philip) Modified on 3/7/2016 (lak).
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Filing 547
Proposed Voir Dire by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 546
Exhibit List by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 545
Redaction to #544 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 544
Brief in Support of #543 Motion in Limine to Exclude the Deposition Testimony of Philippe Guionnet and to Preclude Mr. Guionnet from Testifying at Trial Regarding the Development of Med Mantra by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/7/2016: Deleted duplicate text. (lak)
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Filing 543
Motion in Limine to Exclude the Deposition Testimony of Philippe Guionnet and to Preclude Mr. Guionnet from Testifying at Trial Regarding the Development of Med Mantra by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 542
Redaction to #541 Brief in Support by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 541
Brief in Support of #540 Motion in Limine to Exclude Cumulative Testimony Regarding Access to UserWeb by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 3/7/2016: Deleted duplicate text. (lak)
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Filing 540
Motion in Limine to Exclude Cumulative Testimony Regarding Access to UserWeb by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/7/2016. (lak)
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Filing 539
** TEXT ONLY ORDER ** Defendants may have until March 11, 2016, to file a response to Epic's motion for sanctions (dkt. #521 ). In addition to the arguments made in plaintiff's supporting memorandum, defendants should address the impact of the court's summary judgment decision today finding as a matter of law that defendants failed to give prompt and full notice of their ongoing, unauthorized access to Epic's UserWeb in breach of contract and violation of state and federal statute. In particular, the court seeks comment as to whether the court or jury may consider the impact of defendants' almost two year silence on plaintiff's ability (1) to take steps to prevent any misuse of information or documents that were wrongfully accessed or (2) to prevent spoliation of evidence of misuse. No reply will be allowed unless requested by the court. Signed by District Judge William M. Conley on 3/2/2016. (mfh)
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Filing 538
OPINION and ORDER granting in part and denying in part #195 Motion for Partial Summary Judgment; granting in part and denying in part #197 Motion for Partial Summary Judgment; denying #413 Motion for an Order Denying or Deferring Consideration of Defendants' Partial Motion for Summary Judgment Pursuant to Federal Rule of Civil Procedure 56(d); granting in part and denying in part as moot #448 Motion to Compel Responses to its Fourth Set of Interrogatories; denying #484 Motion to Compel Responses to Defendants' Third Set of Interrogatories; granting in part and reserving in part #326 Motion to Dismiss Defendants' Counterclaims and Immediately Sever and Stay All Counterclaim Proceedings. Signed by District Judge William M. Conley on 3/2/2016. (kwf)
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Filing 537
Redaction to #531 Brief in Support Of Its Motion for Sanctions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 536
Redaction to #523 Declaration of Samuel S. Rubin by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Slipsheet) (Richmond, Rick)
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Filing 535
Redaction to #524 Declaration and Exhibit Entries #526 , #527 , #528 , #529 , #530 , by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit 1 - Slipsheet, #2 Exhibit 2 - Slipsheet, #3 Exhibit 3 - Slipsheet, #4 Exhibit 4 - Slipsheet, #5 Exhibit 5 - Slipsheet, #6 Exhibit 6 - Slipsheet, #7 Exhibit 7 - Slipsheet, #8 Exhibit 8 - Slipsheet, #9 Exhibit 9 - Slipsheet, #10 Exhibit 10 - Slipsheet, #11 Exhibit 11 - Slipsheet, #12 Exhibit 12 - Slipsheet, #13 Exhibit 13 - Slipsheet, #14 Exhibit 14 - Slipsheet, #15 Exhibit 15 - Slipsheet, #16 Exhibit 16 - Slipsheet, #17 Exhibit 17 - Slipsheet, #18 Exhibit 18 - Slipsheet, #19 Exhibit 19 - Slipsheet, #20 Exhibit 20 - Corporate brochure by Tata Consultancy Services, "A New Way Forward.", #21 Exhibit 21 - Press release, "TCS Recognized as Leader in Digital Services by Everest Group.", #22 Exhibit 22 - TCS's webpage, "The TCE Co-Innovation Network (COINTM).", #23 Exhibit 23 - TCS's webpage, "Experience certainty.", #24 Exhibit 24 - Press release, "TCS Recognized as a Leader in Manufacturing SLM IT Strategic Consulting by IDC Marketscape.", #25 Exhibit 25 -Slipsheet, #26 Exhibit 26 - 2/13/2015 Email correspondence from Melissa Byroade to Kate Spelman, #27 Exhibit 27 - 1/20/2016 Email from Rick Richmond to Philip Robben attaching deposition notices, #28 Exhibit 28 - 1/26/2016 Email from Rick Richmond to Philip Robben attaching requests for admission, #29 Exhibit 29 - 2/4/2016 Email from Philip Robben to Rick Richmond attaching proposed interrogatory, #30 Exhibit 30 - 2/8/2016 Email from Philip Robben to Rick Richmond, #31 Exhibit 31 - Defendants' Responses and Objections to Plaintiff's Seventh Set of Interrogatories, #32 Exhibit 32 - Slipsheet, #33 Exhibit 33 - Slipsheet, #34 Exhibit 34 - Slipsheet, #35 Exhibit 35 - Slipsheet, #36 Exhibit 36 - Slipsheet, #37 Exhibit 37 - 2/16/2016 Email from Philip Robben to Julie Shepard, #38 Exhibit 38 - Epic's Objections and Responses to Defendants' Third Set of Interrogatories, served 2/2/2016, #39 Exhibit 39 - 6/26/2015 Correspondence from Melissa Byroade to Nick Saros and Kate Spelman, #40 Exhibit 40 - Notice of Deposition of Mahendra Pandian, #41 Exhibit 41 - 12/23/2015 Email from Alison MacGregor to Julie Shepard and Andrew Sullivan, #42 Exhibit 42 - 12/31/2015 Email from Alison MacGregor to Julie Shepard and Andrew Sullivan, #43 Exhibit 43 - 1/27/2016 Email from Dean Razavi to AnnaMarie Van Hoesen, #44 Exhibit 44 - Slipsheet, #45 Exhibit 45 - 12/21/2015 and 12/29/2015 Emails from Alison MacGregor to Julie Shepard and Andrew Sullivan attaching supplemental interrogatory responses, #46 Exhibit 46 - TCS India's Amended Response and Objections to Plaintiff's First Set of Interrogatories No. 16, #47 Exhibit 47 -TCS America's Amended Response and Objections to Plaintiff's First Set of Interrogatories No. 16, #48 Exhibit 48 - 12/7/2015 Email from Andrew Sullivan to Melissa Byroade, Kristina Allen and Alina Mejer, #49 Exhibit 49 - 12/17/2015 Email from Rick Richmond to Philip Robben, #50 Exhibit 50 - 12/9/2015 Email from Melissa Byroade to Andrew Sullivan, #51 Exhibit 51 - 12/21/2015 Email from Eric Cohen to counsel for Epic regarding Defendants' production of documents bates-stamped TCS00050984 through TCS00135123, #52 Exhibit 52 - 12/4/2015 Email from Rick Richmond to Philip Robben, #53 Exhibit 53 - 12/16/2015 Email from Rick Richmond to Philip Robben, #54 Exhibit 54 - 12/21/2015 Email from Rick Richmond to Philip Robben, #55 Exhibit 55 - 12/24/2015 Email regarding TCS's production of documents bates-stamped TCS00302591 through TCS00318787, #56 Exhibit 56 - Plaintiff's Request for Inspection, #57 Exhibit 57 - 9/23/2015 Letter from Julie Shepard to Melissa Byroade, #58 Exhibit 58 - 10/22/2015 Email from Julie Shepard to Melissa Byroade, #59 Exhibit 59 - 12/9/2015 Email from Nick Saros to Philip Robben, Alison MacGregor, and Melissa Byroade, #60 Exhibit 60 - 12/28/2015 Email from Julie Shepard to Alison MacGregor and Melissa Byroade, #61 Exhibit 61 - 1/10/2016 Email from Julie Shepard to Alison MacGregor and Melissa Byroade, #62 Exhibit 62 - 10/30/2015 Email from Alison MacGregor to Julie Shepard, #63 Exhibit 63 - 10/28/2015 Email from Julie Shepard to Alison MacGregor, #64 Exhibit 64 - 7/24/2015 Letter from Kate Spelman to Melissa Byroade, #65 Exhibit 65 - 10/28/2015 Email from Melissa Byroade to Kelly Morrison, #66 Exhibit 66 - 12/2/2015 Email from Melissa Byroade to Andrew Sullivan, #67 Exhibit 67 - Slipsheet, #68 Exhibit 68 - Slipsheet, #69 Exhibit 69 - Slipsheet, #70 Exhibit 70 - Slipsheet, #71 Exhibit 71 - TCS's Supplemental Responses and Objections to Epic's Fourth Set of Interrogatories, #72 Exhibit 72 - Chart Identifying Epic Documents Found on Images Provided To, Or Taken By, Stroz, #73 Exhibit 73 - Slipsheet, #74 Exhibit 74 - Slipsheet, #75 Exhibit 75 - Slipsheet, #76 Exhibit 76 - Slipsheet, #77 Exhibit 77 - Slipsheet) (Richmond, Rick) Modified on 3/1/2016. (lak)
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Filing 534
Redaction to #532 Motion for Leave to File Motion for Partial Summary Judgment Re: Defendants' Sixth Affirmative Defense (Sealed Document) by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit A - Motion for Partial Summary Judgment, #2 Exhibit B - Memorandum in Support of Motion for Partial Summary Judgment, #3 Exhibit C - Declaration of Rick Richmond in Support of Motion for Partial Summary Judgment, #4 Exhibit D - Declaration of Clement S. Roberts, #5 Exhibit E - Proposed Findings of Fact in Support of Motion for Partial Summary Judgment) (Richmond, Rick) Modified on 3/1/2016: Two docket events were selected when docketing this. (lak)
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Filing 533
** TEXT ONLY ORDER **The parties' joint motion to reschedule the final pretrial conference (dkt. #525 ) is GRANTED. The conference will now take place on March 24, 2016, at 10:00 a.m. Signed by District Judge William M. Conley on 2/29/2016. (kwf)
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Set Briefing Deadlines as to #532 Motion for Leave to File Motion for Partial Summary Judgment Re: Defendants' Sixth Affirmative Defense. Response due 3/15/2016. (kwf/bgw)
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Filing 532
Motion for Leave to File Motion for Partial Summary Judgment Re: Defendants' Sixth Affirmative Defense (Sealed Document) by Plaintiff Epic Systems Corporation. (Attachments: #1 Exhibit A - Motion for Partial Summary Judgment, #2 Exhibit B - Memorandum in Support of Motion for Partial Summary Judgment, #3 Exhibit C - Declaration of Rick Richmond in Support of Motion for Partial Summary Judgment, #4 Exhibit D - Declaration of Clement S. Roberts, #5 Exhibit E - Proposed Findings of Fact in Support of Motion for Partial Summary Judgment) (Richmond, Rick)
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Filing 531
Brief in Support of #521 Motion for Sanctions by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 530
Exhibit to #524 Declaration filed by Epic Systems Corporation. Exhibit 61 - 1/10/2016 Email from Julie Shepard to Alison MacGregor and Melissa Byroade, (Sealed Document) (Attachments: #1 Exhibit 62 - 10/30/2015 Email from Alison MacGregor to Julie Shepard, #2 Exhibit 63 - 10/28/2015 Email from Julie Shepard to Alison MacGregor, #3 Exhibit 64 - 7/24/2015 Letter from Kate Spelman to Melissa Byroade, #4 Exhibit 65 - 10/28/2015 Email from Melissa Byroade to Kelly Morrison, #5 Exhibit 66 - 12/2/2015 Email from Melissa Byroade to Andrew Sullivan, #6 Exhibit 67 - Deposition Exhibit 311, #7 Exhibit 68 - Deposition Exhibit 802, #8 Exhibit 69 - Deposition Exhibit 819, #9 Exhibit 70 - Document produced as TCS00050753-TCS00050754, #10 Exhibit 71 - TCS's Supplemental Responses and Objections to Epic's Fourth Set of Interrogatories, #11 Exhibit 72 - Chart Identifying Epic Documents Found on Images Provided To, Or Taken By, Stroz, #12 Exhibit 73 - 7/9/2015 Letter from Kate Spelman to Melissa Byroade, #13 Exhibit 74 - 8/25/2015 Email from Kate Spelman to Melissa Byroade, #14 Exhibit 75 - Deposition Exhibit 467, #15 Exhibit 76 - 2/3/2016 Letter from Melissa Byroade to AnnaMarie Van Hoesen, #16 Exhibit 77 - 2/16/2016 Email from Melissa Byroade to Nick Saros) (Richmond, Rick) Modified on 2/29/2016. (lak)
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Filing 529
Exhibit to #524 Declaration filed by Epic Systems Corporation. Exhibit 51 - 12/21/2015 Email from Eric Cohen to counsel for Epic regarding Defendants' production of documents bates-stamped TCS00050984 through TCS00135123, (Sealed Document) (Attachments: #1 Exhibit 52 - 12/4/2015 Email from Rick Richmond to Philip Robben, #2 Exhibit 53 - 12/16/2015 Email from Rick Richmond to Philip Robben, #3 Exhibit 54 - 12/21/2015 Email from Rick Richmond to Philip Robben, #4 Exhibit 55 - 12/24/2015 Email regarding TCS's production of documents bates-stamped TCS00302591 through TCS00318787, #5 Exhibit 56 - Plaintiff's Request for Inspection, #6 Exhibit 57 - 9/23/2015 Letter from Julie Shepard to Melissa Byroade, #7 Exhibit 58 - 10/22/2015 Email from Julie Shepard to Melissa Byroade, #8 Exhibit 59 - 12/9/2015 Email from Nick Saros to Philip Robben, Alison MacGregor, and Melissa Byroade, #9 Exhibit 60 - 12/28/2015 Email from Julie Shepard to Alison MacGregor and Melissa Byroade) (Richmond, Rick) Modified on 2/29/2016. (lak)
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Filing 528
Exhibit to #524 Declaration filed by Epic Systems Corporation. Exhibit 41 - 12/23/2015 Email from Alison MacGregor to Julie Shepard and Andrew Sullivan, (Sealed Document) (Attachments: #1 Exhibit 42 - 12/31/2015 Email from Alison MacGregor to Julie Shepard and Andrew Sullivan, #2 Exhibit 43 - 1/27/2016 Email from Dean Razavi to AnnaMarie Van Hoesen, #3 Exhibit 44 - Deposition Exhibit 845, #4 Exhibit 45 - 12/21/2015 and 12/29/2015 Emails from Alison MacGregor to Julie Shepard and Andrew Sullivan attaching supplemental interrogatory responses, #5 Exhibit 46 - TCS India's Amended Response and Objections to Plaintiff's First Set of Interrogatories No. 16, #6 Exhibit 47 - TCS America's Amended Response and Objections to Plaintiff's First Set of Interrogatories No. 16, #7 Exhibit 48 - 12/7/2015 Email from Andrew Sullivan to Melissa Byroade, Kristina Allen and Alina Mejer, #8 Exhibit 49 - 12/17/2015 Email from Rick Richmond to Philip Robben, #9 Exhibit 50 - 12/9/2015 Email from Melissa Byroade to Andrew Sullivan) (Richmond, Rick) Modified on 2/29/2016. (lak)
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Filing 527
Exhibit to #524 Declaration filed by Epic Systems Corporation. Exhibit 31 - Defendants' Responses and Objections to Plaintiff's Seventh Set of Interrogatories, (Sealed Document) (Attachments: #1 Exhibit 32 - Deposition Exhibit 555, #2 Exhibit 33 - Deposition Exhibit 574, #3 Exhibit 34 - Deposition Exhibit 557, #4 Exhibit 35 - Deposition Exhibit 569, #5 Exhibit 36 - Deposition Exhibit 571, #6 Exhibit 37 - 2/16/2016 Email from Philip Robben to Julie Shepard, #7 Exhibit 38 - Epic's Objections and Responses to Defendants' Third Set of Interrogatories, served 2/2/2016, #8 Exhibit 39 - 6/26/2015 Correspondence from Melissa Byroade to Nick Saros and Kate Spelman, #9 Exhibit 40 - Notice of Deposition of Mahendra Pandian) (Richmond, Rick) Modified on 2/29/2016. (lak)
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Filing 526
Exhibit to #524 Declaration filed by Epic Systems Corporation. Exhibit 21 - Press release, "TCS Recognized as Leader in Digital Services by Everest Group.", (Sealed Document) (Attachments: #1 Exhibit 22 - TCS's webpage, "The TCE Co-Innovation Network (COINTM).", #2 Exhibit 23 - TCS's webpage, "Experience certainty.", #3 Exhibit 24 - Press release, "TCS Recognized as a Leader in Manufacturing SLM IT Strategic Consulting by IDC Marketscape.", #4 Exhibit 25 -Defendants' Privilege Log, #5 Exhibit 26 - 2/13/2015 Email correspondence from Melissa Byroade to Kate Spelman, #6 Exhibit 27 - 1/20/2016 Email from Rick Richmond to Philip Robben attaching deposition notices, #7 Exhibit 28 - 1/26/2016 Email from Rick Richmond to Philip Robben attaching requests for admission, #8 Exhibit 29 - 2/4/2016 Email from Philip Robben to Rick Richmond attaching proposed interrogatory, #9 Exhibit 30 - 2/8/2016 Email from Philip Robben to Rick Richmond) (Richmond, Rick) Modified on 2/29/2016. (lak)
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Filing 525
Joint Motion to Reschedule Final Pretrial Conference by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 524
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #521 Motion for Sanctions (Sealed Document) (Attachments: #1 Exhibit 1 - Deposition Exhibit 52, #2 Exhibit 2 - Deposition Exhibit 51, #3 Exhibit 3 - Deposition Exhibit 80, #4 Exhibit 4 - Deposition Exhibit 449, #5 Exhibit 5 - Deposition Exhibit 450, #6 Exhibit 6 - Deposition Exhibit 460, #7 Exhibit 7 - Deposition Exhibit 463A, #8 Exhibit 8 - Deposition Exhibit 456, #9 Exhibit 9 - Deposition Exhibit 457, #10 Exhibit 10 - Deposition Exhibit 458, #11 Exhibit 11 - Deposition Exhibit 459, #12 Exhibit 12 - Deposition Exhibit 461, #13 Exhibit 13 - Deposition Exhibit 463, #14 Exhibit 14 - Deposition Exhibit 713, #15 Exhibit 15 - Deposition Exhibit 465, #16 Exhibit 16 - Deposition Exhibit 466, #17 Exhibit 17 - Deposition Exhibit 468, #18 Exhibit 18 - Deposition Exhibit 472, #19 Exhibit 19 - Deposition Exhibit 563, #20 Exhibit 20 - Corporate brochure by Tata Consultancy Services, "A New Way Forward.") (Richmond, Rick)
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Filing 523
Declaration of Samuel S. Rubin filed by Plaintiff Epic Systems Corporation re: #521 Motion for Sanctions (Sealed Document) (Attachments: #1 Exhibit 1 - Curriculum Vitae of Samuel S. Rubin) (Richmond, Rick)
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Filing 522
** TEXT ONLY ORDER **ORDER granting #520 Motion to Admit AnnaMarie A. Van Hoesen Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 2/26/2016. (lak)
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Filing 521
Motion for Sanctions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 520
Motion to Admit AnnaMarie A. Van Hoesen Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt number 0758-1754018.) by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Van Hoesen, AnnaMarie)
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Filing 519
Scheduling Order: Rule 26(a)(3) Disclosures and Motions in Limine due 3/4/2016, Responses due 3/15/2016. Contested exhibits due 3/23/2016. Final Pretrial Conference reset for 3/25/2016 at 10:00 AM. Deposition Designations are now due 3/4/2016, Objections and Counter-Designations due 3/15/2016, Objections to Counter-Designations due 3/18/2016. Additional deadlines contained in the order. Signed by District Judge William M. Conley on 2/25/2016. (arw)
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Filing 518
Deposition of Stirling Martin taken on January 21, 2016. (Sealed Document) (Saros, Nick)
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Filing 517
Deposition of Sumit Rana taken on January 22, 2016. (Sealed Document) (Saros, Nick)
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Filing 516
Redaction to #514 Declaration of Philip D. Robben in support of defendants' motion in limine to exclude evidence that Epic information was used to develop or enhance Med Mantra or other TCS products by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet) (Robben, Philip) Modified on 2/18/2016. (lak)
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Set Briefing Deadlines re: #511 Motion in Limine to Exclude Evidence that Epic Information Was Used to Develop or Enhance Med Mantra or Other TCS Products. Response due 3/11/2016. No reply. (arw/bgw)
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Filing 514
Declaration of Philip D. Robben in Support filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #511 Motion in Limine to Exclude Evidence that Epic Information Was Used to Develop or Enhance Med Mantra or Other TCS Products, (Sealed Document) (Attachments: #1 Exhibit A - TCS's third set of interrogatories to Epic, dated December 29, 2015, #2 Exhibit B - Epic's objections and responses to TCS's third set of interrogatories, dated February 2, 2016) (Robben, Philip) Modified on 2/18/2016. (lak)
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Filing 513
Redaction to #512 Brief in Support, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 2/18/2016. (lak)
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Filing 512
Brief in Support of #511 Motion in Limine to Exclude Evidence that Epic Information Was Used to Develop or Enhance Med Mantra or Other TCS Products by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 2/18/2016. (lak)
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Filing 511
Motion in Limine to Exclude Evidence that Epic Information Was Used to Develop or Enhance Med Mantra or Other TCS Products by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 510
Deposition of Mahendra Pandian taken on February 12, 2016. (Sealed Document) (Saros, Nick)
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Filing 509
Deposition of Dambarudhar Behera taken on February 12, 2016. (Sealed Document) (Saros, Nick)
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Filing 508
Amended Document by Plaintiff Epic Systems Corporation. Amendment to #502 Deposition of Narasimhan Srinivasan. (Sealed Document) (Saros, Nick) Modified on 2/17/2016. (lak)
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Filing 507
Redaction to #496 Motion to Amend/Correct #391 Order to Show Cause, (Sealed Document) by Interested Party Stroz Friedberg, LLC. (Skilton, John)
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Filing 506
Redaction to #494 Declaration by Interested Party Stroz Friedberg, LLC, (Attachments: #1 Exhibit 1 - 2015-12-10 Email Chain) (Skilton, John)
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Filing 505
Redaction to #495 Declaration, by Interested Party Stroz Friedberg, LLC, (Attachments: #1 Exhibit 1 - Handwritten Notes, #2 Exhibit 2 - Outline, #3 Exhibit 3 - 2015-12-12 Calendar Appointment, #4 Exhibit 4 - 2015-12-21 Calendar Appointment) (Skilton, John)
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Filing 504
Redaction to #493 Statement of Facts by Interested Party Stroz Friedberg, LLC. (Skilton, John) Modified on 2/17/2016. (lak)
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Filing 503
Redaction to #492 Response to Order by Interested Party Stroz Friedberg, LLC. (Skilton, John)
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Matter for the State Bar of California; see #391 Order to Show Cause issued on 1/11/2016. (arw)
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Filing 502
Disregard. See #508 . (Sealed Document) (Saros, Nick) Modified on 2/17/2016. (lak)
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Filing 501
Deposition of Bharathi Ponnambalan taken on January 13, 2016. (Sealed Document) (Saros, Nick)
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Filing 500
Redaction to #497 Brief in Opposition to TCS's Motion to Compel Responses to its Third Set of Interrogatories by Plaintiff Epic Systems Corporation (Saros, Nick)
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Filing 499
Redaction to #498 Declaration of Nick Saros by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Deposition Exhibit 732, #2 Exhibit 2 - Deposition Exhibit 738) (Saros, Nick)
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Filing 498
Declaration of Nick Saros re: #484 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit 1 - Deposition Exhibit 732, #2 Exhibit 2 - Deposition Exhibit 738) (Saros, Nick) Modified on 2/12/2016. (lak)
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Filing 497
Brief in Opposition by Plaintiff Epic Systems Corporation re: #484 Motion to Compel, filed by Tata Consultancy Services Limited, Tata America International Corporation (Sealed Document) (Saros, Nick)
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Filing 496
Motion to Expunge or Amend January 11, 2016 Order to Show Cause and Minute Entry by Interested Party Stroz Friedberg, LLC. Response due 2/18/2016. (Sealed Document) (Skilton, John) Modified on 2/18/2016. (arw)
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Filing 495
Declaration of Wendy T. Wu filed by Interested Party Stroz Friedberg, LLC re: #391 Order to Show Cause, (Sealed Document) (Attachments: #1 Exhibit 1: Handwritten Notes, #2 Exhibit 2: Outline, #3 Exhibit 3: 2015-12-15 Calendar Appointment, #4 Exhibit 4: 2015-12-21 Calendar Appointment) (Skilton, John)
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Filing 494
Declaration of James M. Aquilina filed by Interested Party Stroz Friedberg, LLC re: #391 Order to Show Cause, (Sealed Document) (Attachments: #1 Exhibit 1: 2015-12-10 Email Chain) (Skilton, John)
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Filing 493
Statement of Facts re: #391 Order to Show Cause by Interested Party Stroz Friedberg, LLC. (Sealed Document) (Skilton, John) Modified on 2/12/2016. (lak)
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Filing 492
Response re: #391 Order to Show Cause by Interested Party Stroz Friedberg, LLC. (Sealed Document) (Skilton, John)
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Filing 491
Notice of Appearance filed by John S. Skilton for Interested Party Stroz Friedberg, LLC. (Skilton, John) Modified on 2/12/2016. (lak)
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Filing 490
Deposition of Judith R. Faulkner taken on January 24, 2016. (Sealed Document) (Shepard, Julie)
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Filing 489
Redaction to #487 Declaration of Philip D. Robben in Support of Defendants' Motion to Compel Responses to its Third Set of Interrogatories by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - SlipSheet, #3 Exhibit C - SlipSheet, #4 Exhibit D - SlipSheet, #5 Exhibit E - SlipSheet, #6 Exhibit F - SlipSheet, #7 Exhibit G - SlipSheet, #8 Exhibit H - SlipSheet, #9 Exhibit I - SlipSheet, #10 Exhibit J - SlipSheet) (Robben, Philip)
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Filing 488
Disregard. See #489 . Redaction to #487 Declaration of Philip D. Robben in Support of Defendants' Motion to Compel Responses to its Third Set of Interrogatories by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Modified on 2/5/2016. (arw) Modified on 2/8/2016. (lak)
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Filing 487
Declaration of Philip D. Robben in Support of Defendants' Motion to Compel Responses to its Third Set of Interrogatories filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #484 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - 12/29/15 TCS's Third Set of Interrogatories to Epic, #2 Exhibit B - 2/2/16 Epic's Responses to TCS's Third Set of Interrogatories, #3 Exhibit C - Exhibit 57, #4 Exhibit D - Exhibit 77, #5 Exhibit E - Exhibit 97, #6 Exhibit F - Exhibit 1097, #7 Exhibit G - Exhibit 1082, #8 Exhibit H - Exhibit 1098, #9 Exhibit I - Selected Pages from Exhibit 325, #10 Exhibit J - 9/9/15 Transcript of Telephone Motion Hearing before Judge Crocker) (Robben, Philip)
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Filing 486
Redaction to #485 Brief in Support of Motion to Compel Responses to its Third Set of Interrogatories by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 2/5/2016: Removed duplicate docket text. (lak)
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Filing 485
Brief in Support of #484 Motion to Compel Responses to its Third Set of Interrogatories by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 2/5/2016: Removed duplicate docket text. (lak)
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Filing 484
Motion to Compel Responses to Defendant's Third Set of Interrogatories by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 2/11/2016. (Robben, Philip)
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Filing 483
Deposition of Eric Helsher taken on January 19, 2016. (Sealed Document) (Robben, Philip)
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Filing 482
Deposition of Ritesh Kumar Manjpuria taken on January 29, 2016. (Sealed Document) (Shepard, Julie)
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Filing 481
Deposition of Venkatakrishnan Narasimhan taken on January 27, 2016. (Sealed Document) (Shepard, Julie)
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Filing 480
Deposition of Bill McCarthy taken on January 27, 2016. (Sealed Document) (Shepard, Julie)
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Filing 479
Deposition of Agnihotra Ghosh taken on January 26, 2016. (Sealed Document) (Shepard, Julie)
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Filing 478
Deposition of Gautam Chhibber taken on January 25, 2016. (Sealed Document) (Shepard, Julie)
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Filing 477
Deposition of Brad Kowalski taken on January 22, 2016. (Sealed Document) (Shepard, Julie)
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Filing 476
Deposition of Revanthi Purushotham taken on January 21, 2016. (Sealed Document) (Shepard, Julie)
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Filing 475
Deposition of Madhavi Mukherji taken on January 13, 2016. (Sealed Document) (Shepard, Julie)
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Filing 474
Deposition of Saswat Mishra taken on January 12, 2016. (Sealed Document) (Shepard, Julie)
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Filing 473
Deposition of Suraj Kartha taken on January 11, 2016. (Sealed Document) (Shepard, Julie)
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Filing 472
Deposition of Curtis Bajak taken on January 7, 2016. (Sealed Document) (Shepard, Julie)
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Filing 471
** TEXT ONLY ORDER **ORDER granting #470 Motion to Admit August Theodore Horvath Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 2/1/2016. (lak)
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Filing 470
Motion to Admit August Theodore Horvath Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt number 0758-1732896.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited, Counter Claimant Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (Horvath, August)
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Filing 469
Redaction to #468 Brief in Reply in Support of Plaintiffs' Expedited Motion to Dismiss Defendants' Counterclaims and to Immediately Sever and Stay All Counterclaim Proceedings by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony) Modified on 1/31/2016. (lak)
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Filing 468
Brief in Reply by Plaintiff Epic Systems Corporation in Support of #326 Motion to Dismiss Defendants' Counterclaims and to Immediately Sever and Stay All Counterclaim Proceedings. (Sealed Document) (Tomaselli, Anthony) Modified on 1/31/2016. (lak)
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Filing 467
Redaction to #464 Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Byroade, Melissa)
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Filing 466
Redaction to #465 Declaration of Melissa E. Byroade in Opposition to Plaintiff's Motion to Compel Response to its Fourth Set of Interrogatories by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - Jan 2016 emails between R Richmond and M Byroade, #3 Exhibit C - 2016-01-20 Email from A MacGregor, #4 Exhibit D - SlipSheet, #5 Exhibit E - SlipSheet, #6 Exhibit F - SlipSheet, #7 Exhibit G - SlipSheet) (Byroade, Melissa) Modified on 1/31/2016. (lak)
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Filing 465
Declaration of Melissa E. Byroade in Opposition to Plaintiff's Motion to Compel Response to its Fourth Set of Interrogatories filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #448 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit A- 2016-01-14 TCS Responses and Objections to Fourth Set of Interrogatories, #2 Exhibit B- Jan 2016 emails between R Richmond and M Byroade, #3 Exhibit C- 2016-01-20 Email from A MacGregor, #4 Exhibit D- 2016-01-28 Defendants Supplemental Responses to Fourth Interrogatories, #5 Exhibit E- Oct 2015 Emails from TCS regarding Naresh Yallapragada, #6 Exhibit F- Deposition Exhibit 478, #7 Exhibit G- TCS00018151) (Byroade, Melissa) Modified on 1/29/2016. (lak)
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Filing 464
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #448 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 463
Deposition of Mohan Krishna Jasti taken on January 20, 2016. (Sealed Document) (Robben, Philip)
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Filing 462
Redaction to #460 Response to Proposed Findings of Fact, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Reset Briefing Deadlines re: #448 Motion to Compel Responses to its Fourth Set of Interrogatories by Plaintiff Epic Systems Corporation. Response due 1/29/2016 by 12:00 PM. (arw/bgw)
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Filing 460
Response to Additional Proposed Findings of Fact filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip) Modified on 1/26/2016. (lak)
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Filing 459
Redaction to #458 Reply in Support of Proposed Findings of Fact,, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 458
Reply in Support of Proposed Findings of Fact filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip) Modified on 1/26/2016. (lak)
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Filing 457
Redaction to #456 Declaration by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet) (Robben, Philip)
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Filing 456
Declaration of Philip D. Robben in Further Support of Defendants' Motion for Partial Summary Judgment filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment (Sealed Document) (Attachments: #1 Exhibit A - Epic's Responses to TCS's Second Set of Document Requests, #2 Exhibit B - Epic's Supplemental Interrogatory Responses to Second Set of Interrogatories) (Robben, Philip)
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Filing 455
Redaction to #454 Brief in Reply in Further Support of their Motion for Partial Summary Judgment by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 1/26/2016. (lak)
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Filing 454
Brief in Reply in Support of #197 Motion for Partial Summary Judgment and in Opposition to #413 Motion for Order Denying or Deferring Consideration of Defendants' Motion for Partial Summary Judgment, filed by Defendants and Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 1/27/2016. (arw)
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Filing 453
Redaction to #450 Declaration of Nick Saros filed by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1-Epic's Fourth Set of Interrogatories to Tata, #2 Exhibit 2-Defendants' Responses and Objections To Plaintiff's Fourth Set of Interrogatories, #3 Exhibit 3-January 7, 2016 email from M. Byroade to J. Shepard, #4 Exhibit 4-January 11, 2016 email from N. Saros to M. Byroade, #5 Exhibit 5-January 14, 2016 email sent at 10:47 a.m. PST from R. Richmond to M. Byroade, #6 Exhibit 6-January 14, 2016 email received at 4:55 p.m. PST from M. Byroade to R. Richmond, #7 Exhibit 7-January 14, 2016 email sent at 6:34 p.m. PST from R. Richmond to M. Byroade, #8 Exhibit 8-Document bate-stamped TCS00007931, #9 Exhibit 9-Document bate-stamped TCS00018151-52) (Saros, Nick) Modified on 1/26/2016: Corrected docketing event and linked to the correct document. (lak)
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Filing 452
Redaction to #449 Brief in Support by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 1/26/2016: Corrected the docketing event and linked to the correct document. (lak)
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Filing 451
Deposition of Revathi Purushotham taken on January 21, 2016. (Sealed Document) (Robben, Philip)
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Filing 450
Declaration of Nick Saros filed by Plaintiff Epic Systems Corporation re: #448 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit 1-Epic's Fourth Set of Interrogatories to Tata, #2 Exhibit 2-Defendants' Responses and Objections To Plaintiff's Fourth Set of Interrogatories, #3 Exhibit 3-January 7, 2016 email from M. Byroade to J. Shepard, #4 Exhibit 4-January 11, 2016 email from N. Saros to M. Byroade, #5 Exhibit 5-January 14, 2016 email sent at 10:47 a.m. PST from R. Richmond to M. Byroade, #6 Exhibit 6-January 14, 2016 email received at 4:55 p.m. PST from M. Byroade to R. Richmond, #7 Exhibit 7-January 14, 2016 email sent at 6:34 p.m. PST from R. Richmond to M. Byroade, #8 Exhibit 8-Document bate-stamped TCS00007931, #9 Exhibit 9-Document bate-stamped TCS00018151-52) (Saros, Nick)
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Filing 449
Brief in Support of #448 Motion to Compel Responses to its Fourth Set of Interrogatories by Plaintiff Epic Systems Corporation. (Sealed Document) (Saros, Nick)
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Filing 448
Motion to Compel Responses to its Fourth Set of Interrogatories by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 2/1/2016. (Saros, Nick)
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Filing 447
Transcript of Telephonic Motion Hearing, held 1/22/16 before Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (jat)
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Filing 446
ORDER denying #363 Motion to Compel; granting in part and denying in part #429 Motion for Protective Order and #436 Emergency Motion to Compel. Signed by District Judge William M. Conley on 1/22/2016. (arw)
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Filing 445
Deposition of Ajit Menon taken on January 15, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 444
Deposition of Arun Agarwal taken on January 14, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 443
Redaction to #442 Declaration of Philip D. Robben in Support of Defendants' Motion for a Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - 2015-12-15 Deposition Notice of Natarajan Chandrasekaran, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E - Slipsheet, #6 Exhibit F - Slipsheet, #7 Exhibit G - Slipsheet, #8 Exhibit H - Slipsheet, #9 Exhibit I - Slipsheet) (Robben, Philip) Modified on 1/22/2016. (lak)
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Filing 442
Declaration of Philip D. Robben re: #429 Motion for Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran, (Sealed Document) (Attachments: #1 Exhibit A - 2015-12-15 Deposition Notice of Natarajan Chandrasekaran, #2 Exhibit B - 2016-01-06 Letter from P. Robben, #3 Exhibit C - Jan 8 - Jan 18 email chain between R. Richmond & P. Robben, #4 Exhibit D - 2016-01-20 email from R. Richmond, #5 Exhibit E - Deposition exhibit 31, #6 Exhibit F - Deposition exhibit 53, #7 Exhibit G - Deposition exhibit 325, #8 Exhibit H - Deposition exhibit 327, #9 Exhibit I - Deposition exhibit 367) (Robben, Philip) Modified on 1/22/2016. (lak)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Motion Hearing held on 1/22/2016 re #363 Motion to Compel Plaintiff's Compliance with Defendants' Fourth Set of Document Requests, #429 Motion for Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran filed by Tata Consultancy Services Limited, Tata America International Corporation, #436 Emergency Motion to Compel Deposition of Natarajan Chandrasekaran filed by Epic Systems Corporation [:20]() (Court Reporter LS.) (mfh)
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Set Deadlines and Hearings: Telephone Motion Hearing set for 1/22/2016 at 3:00 PM before District Judge William M. Conley re: #363 Motion to Compel, #429 Motion for Protective Order, #436 Emergency Motion to Compel. Counsel for Defendants responsible for setting up the call to chambers at (608) 264-5087. (arw/wmc)
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Filing 441
Redaction to #438 Brief in Support of Emergency Motion to Compel Deposition of Natarajan Chandrasekaran by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 440
Redaction to #439 Declaration of Rick Richmond In Support of Plaintiff's Emergency Motion to Compel Deposition of Natarajan Chandrasekaran by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Deposition Exhibit 717, #2 Exhibit 2 - Deposition Exhibit 719, #3 Exhibit 3 - Deposition Exhibit 734, #4 Exhibit 4 - Notice of Deposition of Natarajan Chandrasekaran, #5 Exhibit 5 - 01/06/2016 Correspondence regarding deposition of Natarajan Chandrasekaran, #6 Exhibit 6 - Deposition Exhibit 091, #7 Exhibit 7 - Deposition Exhibit 083) (Richmond, Rick)
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Filing 439
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #436 Emergency Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit 1 - Deposition Exhibit 717, #2 Exhibit 2 - Deposition Exhibit 719, #3 Exhibit 3 - Deposition Exhibit 734, #4 Exhibit 4 - Notice of Deposition of Natarajan Chandrasekaran, #5 Exhibit 5 - 01/06/2016 Correspondence regarding deposition of Natarajan Chandrasekaran, #6 Exhibit 6 - Deposition Exhibit 091, #7 Exhibit 7 - Deposition Exhibit 083) (Richmond, Rick) Modified on 1/22/2016. (lak)
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Filing 438
Brief in Support of #436 Emergency Motion to Compel Deposition of Natarajan Chandrasekaran by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 1/22/2016. (lak)
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Filing 437
Deposition of Ajit Menon taken on 01/14/2016. (Sealed Document) (Attachments: #1 Deposition of Ajit Menon (Part 2), #2 Deposition of Ajit Menon (Part 3), #3 Deposition of Ajit Menon (Part 4)) (Robben, Philip)
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Filing 436
Emergency Motion to Compel Deposition of Natarajan Chandrasekaran by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 1/28/2016. (Richmond, Rick)
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Filing 435
Redaction to #434 Declaration of Natarajan Chandrasekaran by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet) (Robben, Philip) Modified on 1/21/2016. (lak)
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Filing 434
Declaration of Natarajan Chandrasekaran filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #429 Motion for Protective Order, (Sealed Document) (Attachments: #1 Exhibit A - Deposition exhibit 159, #2 Exhibit B - Deposition exhibit 159A) (Robben, Philip)
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Filing 433
Disregard. See #442 . (Sealed Document) Modified on 1/22/2016. (lak)
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Filing 432
Disregard. See #443 . Modified on 1/22/2016. (lak)
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Filing 431
Redaction to #430 Brief in Support of Their Motion for a Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 1/21/2016. (lak)
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Filing 430
Brief in Support of #429 Motion for Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 1/21/2016. (lak)
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Filing 429
Motion for Protective Order Quashing Plaintiff's Notice of Deposition of Natarajan Chandrasekaran by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 1/21/2016. (lak)
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Filing 428
** TEXT ONLY ORDER **Defendants' deadline to respond to #413 Epic Systems' Motion for an Order Denying or Deferring Consideration of Defendants' Motion for Partial Summary Judgment is extended by one business day, to Monday, January 25, 2016. Defendants may file a combined brief in response to Epic's motion and in reply in support of their own motion for partial summary judgment, dkt. #197 . Signed by Magistrate Judge Stephen L. Crocker on 1/21/2016. (arw)
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Filing 427
Disregard. See #437 for a version that's easier to read. (Sealed Document) Modified on 1/22/2016. (lak)
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Filing 426
Deposition of Jason Cline taken on January 15, 2016. (Sealed Document) (Richmond, Rick)
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Filing 425
Redaction to #424 Brief in Opposition, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 424
Brief in Opposition by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #326 Motion to Dismiss, filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip) Modified on 1/20/2016. (lak)
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Filing 423
Redaction to #417 Response to Proposed Findings of Fact by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 422
Redaction to #418 Declaration by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A-Rishel CV) (Richmond, Rick)
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Filing 421
Redaction to #416 Declaration by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1-Exhibit 467 of C. Bajak Deposition, #2 Exhibit 2-Exhibit 423 of DV Prasad Deposition, #3 Exhibit 3-Exhibit 411 of P. Hegde Deposition, #4 Exhibit 4-Exhibit 827 of T. Mandal Deposition, #5 Exhibit 5-Document bate-stamped EPIC0088928 through EPIC0088931, #6 Exhibit 6-Exhibit 722 of R. Raju Deposition, #7 Exhibit 7-Document bate-stamped TCS00019960-19971, #8 Exhibit 8-Document bate-stamped TCS00008300, #9 Exhibit 9-Document bate-stamped TCS00007964-65) (Richmond, Rick)
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Filing 420
Redaction to #415 Additional Proposed Findings of Fact by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 419
Redaction to #414 Brief in Opposition by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 418
Declaration of Wes Rishel filed by Plaintiff Epic Systems Corporation re: #197 Motion for Partial Summary Judgment, (Sealed Document) (Attachments: #1 Exhibit A-Rishel CV) (Richmond, Rick)
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Filing 417
Response to Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick)
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Filing 416
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation in Support of Plaintiff's Opposition re: #197 Motion for Partial Summary Judgment (Sealed Document) (Attachments: #1 Exhibit 1-Exhibit 467 of C. Bajak Deposition, #2 Exhibit 2-Exhibit 423 of DV Prasad Deposition, #3 Exhibit 3-Exhibit 411 of P. Hegde Deposition, #4 Exhibit 4-Exhibit 827 of T. Mandal Deposition, #5 Exhibit 5-Document bate-stamped EPIC0088928 through EPIC0088931, #6 Exhibit 6-Exhibit 722 of R. Raju Deposition, #7 Exhibit 7-Document bate-stamped TCS00019960-19971, #8 Exhibit 8-Document bate-stamped TCS00008300, #9 Exhibit 9-Document bate-stamped TCS00007964-65) (Richmond, Rick)
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Filing 415
Additional Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick)
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Filing 414
Brief in Opposition by Plaintiff Epic Systems Corporation re: #197 Motion for Partial Summary Judgment filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Richmond, Rick)
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Filing 413
Motion for an Order Denying or Deferring Consideration of Defendants' Partial Motion for Summary Judgment Pursuant to Federal Rule of Civil Procedure 56(d) by Plaintiff Epic Systems Corporation. Response due 1/22/2016. (Richmond, Rick)
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Filing 412
Deposition of Paul Amalraj taken on January 13, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 411
Deposition of Tapas Mondal taken on January 12, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 410
Deposition of Sankari Gunasekaran taken on January 12, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 409
Deposition of Ravi Raju taken on January 11, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 408
Deposition of Indana Susmita taken on January 11, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 407
Deposition of Arulbigju Kaspar taken on January 08, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 406
Deposition of Ajit Menon taken on January 15, 2016 (Vol. 2). (ROUGH DRAFT) (Sealed Document) (Morrison, Kelly) Modified on 1/15/2016 (voc).
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Filing 405
Deposition of Bharathi Ponnambalan taken on January 13, 2006 (2016) (ROUGH DRAFT) . (Sealed Document) (Morrison, Kelly) Modified on 1/15/2016 (voc).
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Filing 404
Deposition of Ajit Menon taken on January 14, 2016 (ROUGH DRAFT) . (Sealed Document) (Morrison, Kelly) Modified on 1/15/2016 (voc).
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Filing 403
Deposition of Santosh Mohanty taken on January 09, 2016. (Sealed Document) (Morrison, Kelly)
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Filing 402
Deposition of Srikanth Telkapalli taken on September 14, 2015. (Sealed Document) (Morrison, Kelly)
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Filing 401
Deposition of Priscilla Kingston taken on January 07, 2016. (Sealed Document) (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 400
Declaration of Brett Rehm filed by Plaintiff Epic Systems Corporation re: #363 Motion to Compel. (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 399
Brief in Opposition by Plaintiff Epic Systems Corporation re: #363 Motion to Compel, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 398
Disregard. See #399 . Modified on 1/15/2016. (lak)
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Filing 397
Deposition of Deepa Pandurangan taken on January 9, 2016. (Sealed Document) (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 396
Deposition of Melmangalam Ramanthan Kumar taken on January 8, 2016. (Sealed Document) (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 395
Deposition of Alok Kumar taken on January 7, 2016. (Sealed Document) (Saros, Nick) Modified on 1/15/2016. (lak)
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Filing 394
Deposition of Ajay Krishnaswamy taken on January 12, 2016. (Sealed Document) (Saros, Nick) Modified on 1/14/2016. (lak)
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Filing 393
Disregard. See #396 for condensed version. (Sealed Document) Modified on 1/15/2016. (lak)
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Filing 392
Disregard. See #395 for condensed version. (Sealed Document) Modified on 1/15/2016. (lak)
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Filing 391
Order to Show Cause Issued. Attorneys James Aquilina and Wendy Wu are barred from further involvement in Stroz's work with Jenner & Block and Epic in this matter. On or before 2/11/2016, Stroz shall show cause as to why this court should not forward the facts surrounding Aquilina and Wu's involvement in the discussion with a represented individual to the State Bar of California. Signed by District Judge William M. Conley on 1/11/2016. (arw) Modified on 3/28/2016. (arw)Amended on March 28, 2016: The order to show cause was deemed satisfied and discharged, consistent with dkt. #728 .
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Filing 390
Transcript of Telephonic Motion Hearing, held 1/8/2016 before Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Filing 389
ORDER granting in part and denying in part #337 Motion for Protective Order ; granting in part and denying in part #343 Motion to Compel. Signed by District Judge William M. Conley on 01/08/2016. (mfh)
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Filing 388
Redaction to #387 Declaration of Erik Laykin by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Laykin CV, #2 Exhibit B - Documents Requested by Laykin) (Robben, Philip)
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Filing 387
Declaration of Erik Laykin filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #363 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Laykin CV, #2 Exhibit B - Documents Requested by Laykin - Under Seal) (Robben, Philip)
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Filing 386
Redaction to #382 Reply in Support of Proposed Findings of Fact by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 1/8/2016. (lak)
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Filing 385
Redaction to #380 Declaration of Rick Richmond, (Attachments: #1 Exhibit 1 - Med Mantra Organization Structure Chart, #2 Exhibit 2 - November 17, 2013 email correspondence between Anmol Gupta and Philippe Guionnet, #3 Exhibit 3 - December 11, 2015 email correspondence between DV Prasad and Venu Medikonda, #4 Exhibit 4 - Assessment Report on complaint raised by Mr. Guionnet, #5 Exhibit 5 - Kaiser Permanente EPIC Issue - Queries and Responses, #6 Exhibit 6 - Plaintiff's Rule 26(a)(2) Disclosure of Wes Rishel, #7 Exhibit 7 - Preliminary Expert Report of Thomas W. Britven) (Richmond, Rick) Modified on 1/8/2016: Corrected docketing event. (lak)
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Filing 384
Redaction to #381 Response to Additional Proposed Findings of Fact by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 1/8/2016. (lak)
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Filing 383
Redaction to #379 Brief in Reply In Support Of Its Motion for Partial Summary Judgment by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Motion Hearing held on 1/8/2016 re #343 Emergency Motion to Compel Appearance and Testimony filed by Tata Consultancy Services Limited, Tata America International Corporation, #337 Emergency Motion for Protective Order re: TCS's Counterclaim Discovery filed by Epic Systems Corporation [:30] (Court Reporter LS.) (mfh)
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Filing 382
Reply in Support of Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation re: #195 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick) Modified on 1/8/2016. (lak)
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Filing 381
Response to Additional Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation re: #195 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick)
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Filing 380
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #195 Motion for Partial Summary Judgment (Sealed Document) (Attachments: #1 Exhibit 1 - Med Mantra Organization Structure Chart, #2 Exhibit 2 - November 17, 2013 email correspondence between Anmol Gupta and Philippe Guionnet, #3 Exhibit 3 - December 11, 2015 email correspondence between DV Prasad and Venu Medikonda, #4 Exhibit 4 - Assessment Report on complaint raised by Mr. Guionnet, #5 Exhibit 5 - Kaiser Permanente EPIC Issue - Queries and Responses, #6 Exhibit 6 - Plaintiff's Rule 26(a)(2) Disclosure of Wes Rishel, #7 Exhibit 7 - Preliminary Expert Report of Thomas W. Britven) (Richmond, Rick)
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Filing 379
Brief in Reply by Plaintiff Epic Systems Corporation in Support of #195 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick)
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Filing 378
Redaction to #376 Declaration of Philip D. Robben in Support of Defendants' Opposition to Plaintiff's Emergency Motion for a Protective Order Regarding TCS's Counterclaim Discovery by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - SlipSheet) (Robben, Philip)
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Filing 377
Redaction to #372 Declaration, in Support of Epic's Opposition to TCS's Motion to Compel Appearance and Testimony by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - 7/16/2015 Letter, #2 Exhibit B - E-mail from Mr. Prasad, #3 Exhibit C - 6/26/2015 Letter, #4 Exhibit D - Chart Regarding Depositions) (Richmond, Rick) Modified on 1/8/2016: Added exhibit descriptions. (lak)
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Filing 376
Declaration of Philip D. Robben in Support of Defendants' Opposition to Plaintiff's Emergency Motion for a Protective Order Regarding TCS's Counterclaim Discovery filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #337 Motion for Protective Order (Sealed Document) (Attachments: #1 Exhibit A - Selected Pages from TCS Answer and Counterclaims- Under Seal, #2 Exhibit B - Epic Document produced as EPIC0121648 - EPIC0121650 - Under Seal) (Robben, Philip)
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Filing 375
Redaction to #371 Brief in Opposition by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 374
Redaction to #373 Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Robben, Philip)
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Filing 373
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #337 Motion for Protective Order filed by Epic Systems Corporation (Sealed Document) (Robben, Philip)
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Filing 372
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation in Support of Epic's Opposition re: #343 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - 7/16/2015 Letter, #2 Exhibit B - E-mail from Mr. Prasad, #3 Exhibit C - 6/26/2015 Letter, #4 Exhibit D - Chart Regarding Depositions) (Richmond, Rick) Modified on 1/7/2016: Added exhibit descriptions. (lak)
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Filing 371
Brief in Opposition by Plaintiff Epic Systems Corporation re: #343 Motion to Compel, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Richmond, Rick)
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Filing 370
Disregard. See #388 . Modified on 1/11/2016. (lak)
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Filing 369
Disregard. See #387 . (Sealed Document) Modified on 1/11/2016. (lak)
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Filing 368
Redaction to #367 Declaration of Philip D. Robben in Support of Defendants' Motion to Compel by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Attachments: #1 Exhibit A - 11.23.15 TCS Fourth Set of Document Requests to Epic, #2 Exhibit B - SlipSheet, #3 Exhibit C - SlipSheet, #4 Exhibit D - SlipSheet, #5 Exhibit E - SlipSheet) (Robben, Philip)
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Filing 367
Declaration of Philip D. Robben in Support of Defendants' Motion to Compel filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #363 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - 11.23.15 TCS Fourth Set of Document Requests to Epic, #2 Exhibit B - 12.07.15 Email from Epic to TCS- Under Seal, #3 Exhibit C - 12.10.15 Email from TCS to Epic re Meet and Confer- Under Seal, #4 Exhibit D - 12.14.15 Letter to Julie Shepard re Epic Documents- Under Seal, #5 Exhibit E - 12.23.15 Epic's Objections and Responses to Defendants' Fourth Set of Doc Requests- Under Seal) (Robben, Philip)
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Filing 366
Redaction to #365 Brief in Support of Motion to Compel Plaintiff's Compliance with Defendants' Fourth Set of Document Requests by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 365
Brief in Support of #363 Motion to Compel Plaintiff's Compliance with Defendants' Fourth Set of Document Requests by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip)
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Filing 364
Deposition of Christina Shiroma taken on December 2, 2015. (Sealed Document) (Robben, Philip)
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Filing 363
Motion to Compel Plaintiff's Compliance with Defendants' Fourth Set of Document Requests by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 1/14/2016. (Robben, Philip)
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Filing 362
Redaction to #361 Declaration of Scott Brown In Connection With Epic's Report re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit A - Stroz Engagement Letter (Ex. A to Brown Decl)) (Richmond, Rick) Modified on 1/6/2016. (lak)
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Filing 361
Declaration of Scott Brown In Connection With Epic's Report re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation (Sealed Document) (Attachments: #1 Exhibit A - Stroz Engagement Letter (Ex. A to Brown Decl)) (Richmond, Rick) Modified on 1/6/2016: Per counsel, changed restriction from Ex Parte to Sealed. (lak)
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Filing 360
Redaction to #354 Declaration, re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit 1 - Email correspondence between Mr. Rubin and Mr. Menon dated December 29, 2015 - January 1, 2016, #2 Exhibit 2 - Website biography of Shanmugam Sankara, #3 Exhibit 3 - Website biography of Ashim Kapur, #4 Exhibit 4 - Website biography of Aditi Tatti) (Richmond, Rick)
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Filing 359
Redaction to #358 Submission re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 1/6/2016. (lak)
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Filing 358
Submission re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation (Sealed Document) (Attachments: #1 Exhibit A - Stroz Engagement Letter (Ex. A to Brown Decl)) (Richmond, Rick) Modified on 1/6/2016: Per counsel, changed restriction from Ex Parte to Sealed. (lak)
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Set Deadlines and Hearings re: #337 Emergency Motion for Protective Order by Plaintiff Epic Systems Corporation. Response due by noon on 1/7/2016. No reply. Telephone Motion Hearing set for 1/8/2016 at 2:00 PM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (arw/mfh)
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Set Deadlines and Hearings re: #343 Emergency Motion to Compel by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due by noon on 1/7/2016. No reply. The court will consider this motion at the telephone motion hearing already scheduled for 1/8/2016 at 2:00 PM. (arw/mfh)
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Filing 357
Disregard. See #362 . Modified on 1/5/2016. (lak)
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Filing 356
Disregard. See #360 . Modified on 1/5/2016. (lak)
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Filing 355
Status Report Epic's Report re the Court's December 31, 2015 Order by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 354
Declaration of Rick Richmond re: #353 Status Report re: the Court's December 31, 2015 Order, (Sealed Document) (Attachments: #1 Exhibit 1 - Email correspondence between Mr. Rubin and Mr. Menon dated December 29, 2015 - January 1, 2016, #2 Exhibit 2 - Website biography of Shanmugam Sankara, #3 Exhibit 3 - Website biography of Ashim Kapur, #4 Exhibit 4 - Website biography of Aditi Tatti) (Richmond, Rick)
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Filing 353
Status Report Re: The Court's December 31, 2015 Order, by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick) Modified on 1/5/2016. (lak)
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Filing 352
Disregard. See #361 . (Ex Parte Document) Modified on 1/5/2016. (lak)
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Filing 351
Disregard. See #358 . (Ex Parte Document) Modified on 1/5/2016. (lak)
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Filing 350
Deposition of Mohan Krishna Jasti taken on December 23, 2015. (Sealed Document) (Richmond, Rick)
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Filing 349
Deposition of DV Prasad taken on December 16, 2015. (Sealed Document) (Richmond, Rick)
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Filing 348
Deposition of Iyappan Rathina taken on December 9, 2015. (Sealed Document) (Richmond, Rick)
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Filing 347
Deposition of Pushpa Hedge taken on December 10, 2015. (Sealed Document) (Richmond, Rick) Modified on 1/5/2016: Corrected spelling of last name. (lak)
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Filing 346
Declaration of Philip D. Robben in Support of Defendants' Emergency Motion to Compel Appearance and Testimony filed by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #343 Motion to Compel, (Attachments: #1 Exhibit A - December 11, 2015 Deposition Notice Served on Epic, #2 Exhibit B - Correspondence between Epic Counsel & TCS Counsel) (Robben, Philip)
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Filing 345
Redaction to #344 Brief in Support, by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 344
Brief in Support of #343 Emergency Motion to Compel Appearance and Testimony by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip) Modified on 1/4/2016. (lak)
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Filing 343
Emergency Motion to Compel Appearance and Testimony by Counter Claimants Tata America International Corporation, Tata Consultancy Services Limited, Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 1/11/2016. (Robben, Philip)
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Filing 342
ORDER granting in part and denying in part #330 Motion for Sanctions as set forth in the order. Signed by District Judge William M. Conley on 12/31/2015. (mfh)
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Filing 341
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: TCS's Counterclaim Discovery re: #337 Emergency Motion for Protective Order, (Attachments: #1 Exhibit 1 - 12/11/2015 Email form Defendants attached 26 notices of depositions, #2 Exhibit 2 - 12/11/2015 Defendants' 5th set of RFPs, #3 Exhibit 3 - 12/18/2015 and 12/30/2015 email between counsel for Plaintiff and Defendants, #4 Exhibit 4 - 12/30/2015 and 12/31/2015 email between counsel for Plaintiff and Defendants) (Richmond, Rick)
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Filing 340
Brief in Support of #337 Emergency Motion for Protective Order re: TCS's Counterclaim Discovery by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 339
Transcript of Telephone Motion Hearing, held 12/30/2015 before District Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Filing 338
Transcript of Telephone Motion Hearing, held 12/23/2015 before District Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Filing 337
Emergency Motion for Protective Order re: TCS's Counterclaim Discovery by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Set Briefing Deadlines re: #337 Emergency Motion for Protective Order by Plaintiff Epic Systems Corporation. Brief in Opposition due 1/19/2016. Brief in Reply due 1/29/2016. (arw/slc)
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Filing 336
Exhibit to #330 Motion for Sanctions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Audio CD containing Exhibits D and E to #333 the Declaration of Philip D. Robben in Support of the Motion for Sanctions. (Neider, Barbara)
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Set Deadlines as to #330 Motion for Sanctions. Telephone Motion Hearing set for 12/30/2015 at 03:00 PM before Judge William M. Conley. Counsel for Defendant responsible for setting up the call to chambers at (608) 264-5087. (jat)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Motion Hearing held on 12/30/2015 re #330 Motion for Sanctions filed by Tata Consultancy Services Limited, Tata America International Corporation [:30] (Court Reporter CS.) (mfh)
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Filing 335
Redaction to #334 Exhibit A - Email from Epic counsel Nick Saros to TCS counsel dated December 8, 2015 by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 334
Exhibit A to #333 Declaration, filed by Tata Consultancy Services Limited, Tata America International Corporation. Email from Epic counsel Nick Saros to TCS counsel dated December 8, 2015. (Sealed Document) (Robben, Philip) Modified on 12/30/2015. (lak)
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Filing 333
Declaration of Philip D. Robben in Support of Defendants' Motion for Sanctions filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #330 Motion for Sanctions, (Attachments: #1 Exhibit A - SlipSheet, #2 Exhibit B - James N. Aquilina's professional biography, #3 Exhibit C - Wendy T. Wu's professional biography, #4 Exhibit D - Stroz Friedberg's December 15, 2015 call with Ajit Menon, #5 Exhibit E - Stroz Friedberg's December 21, 2015 call with Ajit Menon) (Robben, Philip) Modified on 12/30/2015. (lak)
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Filing 332
Redaction to #331 Brief in Support of Defendants' Motion for Sanctions and Disqualification of Jenner & Block LLP by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 331
Brief in Support of #330 Motion for Sanctions and Disqualification of Jenner & Block LLP by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip)
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Filing 330
Motion for Sanctions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Reset Briefing Deadlines re: #326 Expedited Motion to Dismiss by Plaintiff Epic Systems Corporation. Brief in Opposition due 1/19/2016. Brief in Reply due 1/29/2016. (arw/slc)
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Filing 329
Redaction to #327 Brief in Support by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony) Modified on 12/28/2015. (lak)
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Filing 328
Declaration of Meme Hilley filed by Plaintiff Epic Systems Corporation re: #326 Motion to Dismiss, (Attachments: #1 Exhibit 1 - Deposition Notice - Anubhav Gupta, #2 Exhibit 2 - Deposition Notice - Anuj Kalra, #3 Exhibit 3 - Deposition Notice - Arun Karuppaiah, #4 Exhibit 4 - Deposition Notice - Ayush Sharma, #5 Exhibit 5 - Deposition Notice - Chandrasekhar Mothali, #6 Exhibit 6 - Deposition Notice - Deepak Jindal, #7 Exhibit 7 - Deposition Notice - Dipen Thakkar, #8 Exhibit 8 - Deposition Notice - Eldhose Rajan, #9 Exhibit 9 - Deposition Notice - Eric Helsher, #10 Exhibit 10 - Deposition Notice - Gaurav Singh, #11 Exhibit 11 - Deposition Notice - Judith Faulkner, #12 Exhibit 12 - Deposition Notice - Kalyan Dhanireddy, #13 Exhibit 13 - Deposition Notice - Karun Biyani, #14 Exhibit 14 - Deposition Notice - Manish Kumar, #15 Exhibit 15 - Deposition Notice - Mohan Kantrapati, #16 Exhibit 16 - Deposition Notice - Naveen Venkatesh, #17 Exhibit 17 - Deposition Notice - Perveen Kumar, #18 Exhibit 18 - Deposition Notice - Peter Devault, #19 Exhibit 19 - Deposition Notice - Romika Singh, #20 Exhibit 20 - Deposition Notice - Shankar Manickam, #21 Exhibit 21 - Deposition Notice - Sohadra Upadhyay, #22 Exhibit 22 - Deposition Notice - Sravan Parnandi, #23 Exhibit 23 - Deposition Notice - Sumit Rana, #24 Exhibit 24 - Deposition Notice - Suresh Thippireddy, #25 Exhibit 25 - Deposition Notice - Vamsi Vasireddy, #26 Exhibit 26 - Deposition Notice - Yogi Sanghi, #27 Exhibit 27 - TCS Fifth Set of Document Requests, #28 Exhibit 28 - E-mail, #29 Exhibit 29 - Clinical Market Share) (Tomaselli, Anthony) Modified on 12/28/2015. (lak)
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Filing 327
Brief in Support of #326 Motion to Dismiss Defendant's Counterclaims and to Immediately Sever and Stay All Counterclaim Proceedings by Plaintiff Epic Systems Corporation. (Sealed Document) (Tomaselli, Anthony) Modified on 12/28/2015. (lak)
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Filing 326
Expedited Motion to Dismiss Defendants' Counterclaims and Immediately Sever and Stay All Counterclaim Proceedings by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 12/30/2015. (Tomaselli, Anthony) Modified on 12/28/2015. (lak)
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Filing 325
** TEXT ONLY ORDER **Consistent with the court's rulings during today's telephonic hearing with counsel for the parties, plaintiff's Emergency Motion to Compel Production of Documents in Advance of India Depositions (dkt. #312 ) is GRANTED as follows: (1) defendants shall produce all responsive documents for witnesses noticed since November 5, 2015, in searchable form no later than tomorrow, December 24, 2015, including documents from Santosh Mohanty and Ravi Raju that have yet to be fully reviewed by defendants' counsel; (2) defendants shall produce all responsive documents for witnesses noticed since November 11-12, 2015, no later than Wednesday, December 30, 2015; and (3) defendants shall complete production of all documents for witnesses noticed since December 15-17, 2015, on a rolling basis to be completed on or before Wednesday, January 6, 2016. In addition, for this latter category of nine witnesses, plaintiff's may designate for deposition in the United States three out of the six, so-called "DeVita" witnesses and one out of three, so-called "Tester" witnesses during or after the week of January 11, 2016. The remaining five witnesses noticed since December 15-17, 2015, shall be made available by defendants for live video depositions during or after that same week. Signed by District Judge William M. Conley on 12/23/2015. (kwf)
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Filing 324
** TEXT ONLY ORDER **ORDER granting #323 Motion to Admit Julie Shepard Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 12/23/2015. (lak)
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Filing 323
Motion to Admit Julie Shepard Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt number 0758-1708289.) by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Shepard, Julie)
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Filing 322
Disregard. See #323 . Modified on 12/23/2015. (lak)
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Filing 321
Redaction to #319 Declaration of Alison L. MacGregor in Opposition to Plaintiff's Emergency Motion to Compel Production of Documents in Advance of India Depositions by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Assorted news articles regarding flood, #2 Exhibit B - SlipSheet, #3 Exhibit C - SlipSheet, #4 Exhibit D - SlipSheet, #5 Exhibit E - SlipSheet, #6 Exhibit F - SlipSheet) (MacGregor, Alison) Modified on 12/23/2015. (lak)
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Filing 320
Redaction to #318 Brief in Opposition to Plaintiff's Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (MacGregor, Alison)
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Filing 319
Declaration of Alison L. MacGregor in Opposition to Plaintiff's Emergency Motion to Compel Production of Documents in Advance of India Depositions filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #312 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Assorted news articles regarding flood, #2 Exhibit B - 12.19.15 Email from Epic to TCS, #3 Exhibit C - 12.16.15 Email from TCS to Epic, #4 Exhibit D - 12.18.15 Email from TCS to Epic, #5 Exhibit E - 12.11.15 Email from TCS to Epic, #6 Exhibit F - Correspondence between TCS and Epic) (MacGregor, Alison)
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Filing 318
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #312 Motion to Compel, filed by Epic Systems Corporation. (Sealed Document) (MacGregor, Alison)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Motion Hearing held on 12/23/2015 re #312 Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions (Sealed Document) filed by Epic Systems Corporation [:40] (mfh)
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Filing 317
Redaction to #314 Declaration of Andrew Sullivan by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit A - Chart re: status of TCS document production to witnesses/custodians, #2 Exhibit B - 11/24/2015 Andrew Sullivan Email to Melissa Byroade, #3 Exhibit C - 11/25/2015 Andrew Sullivan Email to Melissa Byroade, #4 Exhibit D - 12/4/2015 Andrew Sullivan Email to Melissa Byroade, #5 Exhibit E - 12/10/2015 Andrew Sullivan Email to Melissa Byroade, #6 Exhibit F - 12/11/2015 Melissa Byroade Email to Andrew Sullivan, #7 Exhibit G - 12/16/2015 Rick Richmond Email to Philip Robben, #8 Exhibit H - 12/21/2015 Email chain between Julie Shepard and Alison MacGregor, #9 Exhibit I - 12/21/2015 Rick Richmond Email to Philip Robben) (Richmond, Rick)
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Filing 316
Redaction to #313 Brief in Support of Motion to Compel TCS to Produce Documents in Advance of India Depositions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 315
Redaction to #312 Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions (Sealed Document) by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Reset Briefing Deadlines as to #312 Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions. Response due 12/23/2015 by 10:00 AM. (kwf)
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Set Telephone Motion Hearing as to #312 Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions. Telephone Motion Hearing set for 12/23/2015 at 01:30 PM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (kwf)
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Filing 314
Declaration of Andrew Sullivan filed by Plaintiff Epic Systems Corporation re: #312 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Chart re: status of TCS document production to witnesses/custodians, #2 Exhibit B - 11/24/2015 Andrew Sullivan Email to Melissa Byroade, #3 Exhibit C - 11/25/2015 Andrew Sullivan Email to Melissa Byroade, #4 Exhibit D - 12/4/2015 Andrew Sullivan Email to Melissa Byroade, #5 Exhibit E - 12/10/2015 Andrew Sullivan Email to Melissa Byroade, #6 Exhibit F - 12/11/2015 Melissa Byroade Email to Andrew Sullivan, #7 Exhibit G - 12/16/2015 Rick Richmond Email to Philip Robben, #8 Exhibit H - 12/21/2015 Email chain between Julie Shepard and Alison MacGregor, #9 Exhibit I - 12/21/2015 Rick Richmond Email to Philip Robben) (Richmond, Rick) Modified on 12/22/2015: Changed name. (lak)
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Filing 313
Brief in Support of #312 Motion to Compel TCS to Produce Documents in Advance of India Depositions by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 312
Emergency Motion to Compel TCS to Produce Documents in Advance of India Depositions (Sealed Document) by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 12/28/2015. (Richmond, Rick)
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Filing 311
ORDER granting #310 Amended Stipulation to Protective Order. Signed by Magistrate Judge Stephen L. Crocker on 12/17/2015. (arw)
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Filing 310
Amended Stipulation to Protective Order by Plaintiff Epic Systems Corporation. (Saros, Nick)
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Filing 309
Redaction to #308 Response to Proposed Findings of Fact in Support of Plaintiff's Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 308
Response to Proposed Findings of Fact filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #195 Motion for Partial Summary Judgment. Defendants' Response to Plaintiff's Proposed Findings of Fact in Support of Plaintiff's Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip)
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Filing 307
Redaction to #306 Declaration of Alison L. MacGregor In Opposition to Plaintiff's Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit 1 - Slipsheet, #2 Exhibit 2 - Slipsheet, #3 Exhibit 3 - Slipsheet, #4 Exhibit 4 - Slipsheet, #5 Exhibit 5 - Slipsheet, #6 Exhibit 6 - Slipsheet, #7 Exhibit 7 - Slipsheet, #8 Exhibit 8 - Slipsheet, #9 Exhibit 9 - Slipsheet, #10 Exhibit 10 - Slipsheet, #11 Exhibit 11 - Slipsheet, #12 Exhibit 12 - Slipsheet, #13 Exhibit 13 - Slipsheet, #14 Exhibit 14 - Slipsheet, #15 Exhibit 15 - Slipsheet) (Robben, Philip)
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Filing 306
Declaration of Alison L. MacGregor filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited In Opposition re: #195 Motion for Partial Summary Judgment, (Sealed Document) (Attachments: #1 Exhibit 1- Exhibit 318 Philippe Guionnet (Part 1), #2 Exhibit 1- Exhibit 318 Philippe Guionnet (Part 2), #3 Exhibit 1- Exhibit 318 Philippe Guionnet (Part 3), #4 Exhibit 2- Exhibit 35 Philippe Guionnet, #5 Exhibit 3- Exhibit 53 Philippe Guionnet, #6 Exhibit 4- Exhibit 319 Philippe Guionnet, #7 Exhibit 5- Exhibit 332 Philippe Guionnet, #8 Exhibit 6- Exhibit 336 Philippe Guionnet, #9 Exhibit 7- Exhibit 72 Philippe Guionnet, #10 Exhibit 8- Exhibit 76 Philippe Guionnet, #11 Exhibit 9- Exhibit 81 Philippe Guionnet, #12 Exhibit 10- Exhibit 84 Philippe Guionnet, #13 Exhibit 11- Exhibit 88 Philippe Guionnet, #14 Exhibit 12- Exhibit 397 Suresh Muthuswami, #15 Exhibit 13- 05-27-15 TCS Responses & Objections to Epic's First Set of Interrogatories, #16 Exhibit 14- 12-02-15 Epic Supplemental Responses and Objections to TCS' Second Set of Interrogatories, #17 Exhibit 15- Responses to TCS Questionnaire, #18 Exhibit 16- Exhibit 39 Guionnet Deposition) (Robben, Philip)
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Filing 305
Redaction to #304 Declaration of Ajit Menon by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 304
Declaration of Ajit Menon filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip)
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Filing 303
Redaction to #302 Declaration of Erik Laykin by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 302
Declaration of Erik Laykin filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip)
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Filing 301
Redaction to #300 Proposed Findings of Fact In Support of Its Opposition to Plaintiff's Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 300
Proposed Findings of Fact filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #195 Motion for Partial Summary Judgment / In Support of Its Opposition to Plaintiff's Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip)
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Filing 299
Redaction to #298 Brief in Opposition to Plaintiff's Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 298
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #195 Motion for Partial Summary Judgment filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 297
** TEXT ONLY ORDER **ORDER accepting and entering #292 Joint Stipulation for Amendment to Protective Order. Signed by Magistrate Judge Stephen L. Crocker on 12/15/2015. (arw)
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Filing 296
Redaction to #295 Answer to Second Amended Complaint, Counterclaim by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Doyle, Paul) Modified on 12/14/2015. (lak)
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Filing 295
ANSWER to Second Amended Complaint, COUNTERCLAIM against Epic Systems Corporation by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Doyle, Paul) Modified on 12/14/2015. (lak)
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Filing 294
Transcript of Telephonic Motion Hearing, held 12/7/2015 before Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Filing 293
Transcript of Motion Hearing, held 12/4/2015 before Judge William M. Conley. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Filing 292
Joint Stipulation for Amendment to Protective Order to add New Provision to Section 7.5: Procedures Applying to WebEx Inspections of Products by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 12/11/2015. (lak)
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Filing 291
ORDER granting in part and denying in part #245 Motion to Compel; denying #256 Motion to Compel; granting #261 Motion to Compel. Plaintiff's request for sanctions is RESERVED and its reply in support of its motion for summary judgment is now due 1/7/2016. Signed by District Judge William M. Conley on 12/10/2015. (arw)
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Filing 290
AMENDED COMPLAINT (Second) against Epic Systems Corporation, filed by Epic Systems Corporation. (Saros, Nick)
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Reset Briefing Deadlines re: #195 Motion for Partial Summary Judgment by Plaintiff Epic Systems Corporation. Brief in Reply due 1/7/2016. (arw)
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Minute Entry for proceedings held before District Judge William M. Conley: Continued Telephone Motion Hearing held on 12/7/2015 re #245 Motion to Compel Discovery Regarding TCS Investigations filed by Epic Systems Corporation, #256 Motion to Compel Documents and a Continued Rule 30(b)(6) Deposition filed by Epic Systems Corporation, #261 Motion to Compel Information Related to EHR Products Other Than "Med Mantra" filed by Epic Systems Corporation [1:00] (Court Reporter cs.) (skv)
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Filing 289
In Camera Submission of Engagement Letter by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Ex Parte Document) (Byroade, Melissa)
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Filing 288
Minute Entry for proceedings held before District Judge William M. Conley: Motion Hearing held on 12/4/2015 re #245 Motion to Compel Discovery Regarding TCS Investigations filed by Epic Systems Corporation, #256 Motion to Compel Documents and a Continued Rule 30(b)(6) Deposition filed by Epic Systems Corporation, #261 Motion to Compel Information Related to EHR Products Other Than "Med Mantra" filed by Epic Systems Corporation. [2:10] (Court Reporter CS.) (jef)
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Set Deadlines: Telephone Motion Hearing on Motion to Compel set for 12/7/2015 at 09:00 AM before Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (jat)
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Set/Reset Deadlines as to #195 MOTION FOR PARTIAL SUMMARY JUDGMENT. Brief in Reply due 1/8/2016. (jef)
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Filing 287
Redaction to #286 Declaration, by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - TCS's Responses and Objections to Epic's First Set of Expedited Discovery Requests, #2 Exhibit B - Epic's First Set of Interrogatories, #3 Exhibit C - Epic's Second Set of Requests for Production of Documents, #4 Exhibit D - TCS's Responses and Objections to Epic's First Set of Interrogatories, #5 Exhibit E - July 9, 2015 letter, #6 Exhibit F - July 22, 2015 letter, #7 Exhibit G - Epic's September 16, 2015 letter, #8 Exhibit H - TCS's responses and objections to Epic's Third Set of Interrogatories) (Robben, Philip) Modified on 12/4/2015. (lak)
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Filing 286
Declaration of Melissa E. Byroade in opposition to Plaintiff's motion to compel information related to EHR products other than "Med Mantra" filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #261 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - TCS's Responses and Objections to Epic's First Set of Expedited Discovery Requests, #2 Exhibit B - Epic's First Set of Interrogatories, #3 Exhibit C - Epic's Second Set of Requests for Production of Documents, #4 Exhibit D - TCS's Responses and Objections to Epic's First Set of Interrogatories, #5 Exhibit E - July 9, 2015 letter, #6 Exhibit F - July 22, 2015 letter, #7 Exhibit G - Epic's September 16, 2015 letter, #8 Exhibit H - TCS's responses and objections to Epic's Third Set of Interrogatories) (Robben, Philip) Modified on 12/3/2015. (lak)
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Filing 285
** TEXT ONLY ORDER **ORDER denying #279 Motion for Mediation. Signed by District Judge William M. Conley on 12/3/15. (jat)
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Filing 284
Redaction to #283 Brief in Opposition to Plaintiff's motion to compel information related to EHR products other than "Med Mantra" by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 283
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #261 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 282
Redaction to #281 Brief in Opposition, by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (MacGregor, Alison)
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Filing 281
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #256 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (MacGregor, Alison) Modified on 12/4/2015. (lak)
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Filing 280
Redaction to #279 Motion for Mediation (Sealed Document) by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Attachments: #1 Exhibit - Email String--EPIC0121648-EPIC0121650) (Doyle, Paul)
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Filing 279
Motion for Mediation (Sealed Document) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 12/9/2015. (Attachments: #1 Exhibit - Email String--EPIC0121648-EPIC0121650) (Doyle, Paul)
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Filing 278
Notice of Appearance filed by Paul F Doyle for Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Doyle, Paul)
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Filing 277
Redaction to #273 Brief in Opposition to Plaintiff's Motion to Compel Discovery Regarding TCS Investigations by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 276
Redaction to #271 Declaration of Suresh Muthuswami by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 275
Redaction to #269 Declaration, by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Exhibit 4 to Philippe Guionnet's deposition transcript, #2 Exhibit B - 2011 TCoE Statement of Work between Tata America & Kaiser Foundation Hospitals, #3 Exhibit C - 2014 TCoE Statement of Work between Tata America & Kaiser Foundation Hospitals, #4 Exhibit D - Exhibit 57 to the deposition of Philippe Guionnet, #5 Exhibit E - Email from TCS's counsel to Epic's counsel, dated November 4, 2015, #6 Exhibit F - TCS00007611, #7 Exhibit G - Epic's First Set of Interrogatories, #8 Exhibit H - TCS's responses and objections to Epic's Second Set of Requests for Production, #9 Exhibit I - EPIC0121648, #10 Exhibit J - Exhibit 170 to the deposition of Suresh Muthuswami, #11 Exhibit K - Cover letter to Epic's Rule 30(b)(6) notice, #12 Exhibit L - Exhibit 303 to the deposition of Suresh Muthuswami, #13 Exhibit M - Exhibit 104 to the deposition of Philippe Guionnet, #14 Exhibit N - Exhibit 96 to the deposition of Philippe Guionnet, #15 Exhibit O - Email from Alison MacGregor to Epic's counsel dated November 20, 2015) (Robben, Philip)
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Filing 274
Disregard. See #277 . Modified on 12/1/2015. (lak)
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Filing 273
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #245 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (Robben, Philip)
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Filing 272
Disregard. See #276 . Modified on 12/1/2015. (lak)
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Filing 271
Declaration of Suresh Muthuswami filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #245 Motion to Compel. (Sealed Document) (Robben, Philip)
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Filing 270
Disregard. See #275 . Modified on 12/1/2015. (lak)
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Filing 269
Declaration of Philip D. Robben in Opposition to Plaintiff's Motion to Compel Discovery regarding TCS Investigations filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #245 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit A - Exhibit 4 to Philippe Guionnet's deposition transcript, #2 Exhibit B - 2011 TCoE Statement of Work between Tata America & Kaiser Foundation Hospitals, #3 Exhibit C - 2014 TCoE Statement of Work between Tata America & Kaiser Foundation Hospitals, #4 Exhibit D - Exhibit 57 to the deposition of Philippe Guionnet, #5 Exhibit E - Email from TCS's counsel to Epic's counsel, dated November 4, 2015, #6 Exhibit F - TCS00007611, #7 Exhibit G - Epic's First Set of Interrogatories, #8 Exhibit H - TCS's responses and objections to Epic's Second Set of Requests for Production, #9 Exhibit I - EPIC0121648, #10 Exhibit J - Exhibit 170 to the deposition of Suresh Muthuswami, #11 Exhibit K - Cover letter to Epic's Rule 30(b)(6) notice, #12 Exhibit L - Exhibit 303 to the deposition of Suresh Muthuswami, #13 Exhibit M - Exhibit 104 to the deposition of Philippe Guionnet, #14 Exhibit N - Exhibit 96 to the deposition of Philippe Guionnet, #15 Exhibit O - Email from Alison MacGregor to Epic's counsel dated November 20, 2015) (Robben, Philip)
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Filing 268
ORDER granting in part and denying in part #266 Motion for Clarification and Motion for Extension of Time. Brief in Opposition re: #195 Motion for Summary Judgment due 12/16/2015. Brief in Reply due 12/31/2015. Responses to the Motions to Compel, #256 and #261 , are due 12/3/2015 by 4:00 PM. The court intends to take up these two new motions during the in-person motion hearing on 12/4/2015. Signed by District Judge William M. Conley on 11/24/2015. (arw)
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Filing 267
Declaration of Alison L. MacGregor filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #266 Motion for Clarification of Dispositive Motion Briefing Deadlines and for Extension of Briefing Schedules. (Neider, Barbara) Modified on 11/25/2015. (lak)
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Filing 266
Motion for Clarification of Dispositive Motion Briefing Deadlines and for Extension of Briefing Schedules for Response to Epic's Recently-Filed Motions to Compel by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 12/1/2015. (Neider, Barbara)
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Filing 265
Redaction to #263 Declaration of Rick Richmond by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit 1 - 09/16/2015 Epic Third Set of RFPs to TCS America, #2 Exhibit 2 - 09/16/2015 Epic Third Set of RFPs to TCS India, #3 Exhibit 3 - 10/16/2015 TCS Responses and Objections to Epic's Third Set of RFPs, #4 Exhibit 4 - 10/13/2015 Defendants' Response and Objections to Epic's Request for Inspection, #5 Exhibit 5 - Screenshot of TCS Media, #6 Exhibit 6 - Deposition Exhibit 1058, #7 Exhibit 7 - Deposition Exhibit 104, #8 Exhibit 8 - Deposition Exhibit 155, #9 Exhibit 9 - 11/03/2015 Correspondence re name game re healthcare and EHR management products, #10 Exhibit 10 - Screenshot of TCS Website (Step 1), #11 Exhibit 11 - Screenshot of TCS Website (Step 2), #12 Exhibit 12 - Screenshot of TCS Website (Step 3), #13 Exhibit 13 - Screenshot of TCS Website (Step 4), #14 Exhibit 14 - Screenshot of TCS Website (Step 5), #15 Exhibit 15 - Print-out of TCS Website "Med Mantra - Hospital Management and Information System", #16 Exhibit 16 - Med Mantra marketing brochure) (Richmond, Rick)
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Filing 264
Redaction to #262 Brief in Support of its Motion to Compel Information Related to EHR Products other than "Med Mantra" by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Reset Briefing Deadlines re: #256 Motion to Compel Documents and Continued Rule 30(b)(6) Deposition, #261 Motion to Compel Information Related to EHR Products Other Than "Med Mantra." Responses due 12/1/2015. (arw/slc)
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Filing 263
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #261 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit 1 - 09/16/2015 Epic Third Set of RFPs to TCS America, #2 Exhibit 2 - 09/16/2015 Epic Third Set of RFPs to TCS India, #3 Exhibit 3 - 10/16/2015 TCS Responses and Objections to Epic's Third Set of RFPs, #4 Exhibit 4 - 10/13/2015 Defendants' Response and Objections to Epic's Request for Inspection, #5 Exhibit 5 - Screenshot of TCS Media, #6 Exhibit 6 - Deposition Exhibit 1058, #7 Exhibit 7 - Deposition Exhibit 104, #8 Exhibit 8 - Deposition Exhibit 155, #9 Exhibit 9 - 11/03/2015 Correspondence re name game re healthcare and EHR management products, #10 Exhibit 10 - Screenshot of TCS Website (Step 1), #11 Exhibit 11 - Screenshot of TCS Website (Step 2), #12 Exhibit 12 - Screenshot of TCS Website (Step 3), #13 Exhibit 13 - Screenshot of TCS Website (Step 4), #14 Exhibit 14 - Screenshot of TCS Website (Step 5), #15 Exhibit 15 - Print-out of TCS Website "Med Mantra - Hospital Management and Information System", #16 Exhibit 16 - Med Mantra marketing brochure) (Richmond, Rick) Modified on 11/24/2015. (lak)
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Filing 262
Brief in Support of #261 Motion to Compel Information Related to EHR Products Other Than "Med Mantra" by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 261
Motion to Compel Information Related to EHR Products Other Than "Med Mantra" by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 11/30/2015. (Richmond, Rick)
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Filing 260
Redaction to #257 Brief in Support of its Motion to Compel Documents and a Continued Rule 30(b)(6) Deposition by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 259
Redaction to #258 Declaration of Nick Saros by Plaintiff Epic Systems Corporation (Attachments: #1 Exhibit 1 - Deposition Exhibit 163, #2 Exhibit 2 - 11/03/2015 Email Correspondence re Commander Kumar documents, #3 Exhibit 3 - 06/26/2015 Correspondence re potential deposition witnesses, #4 Exhibit 4 - 11/04/2015 Email Correspondence re depositions in India, #5 Exhibit 5 - 11/20/2015 Email Correspondence re Rule 30(b)(6) deposition, #6 Exhibit 6 - 11/23/2015 Email Correspondence re Rule 30(b)(6) deposition) (Richmond, Rick)
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Filing 258
Declaration of Nick Saros filed by Plaintiff Epic Systems Corporation re: #256 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit 1 - Deposition Exhibit 163, #2 Exhibit 2 - 11/03/2015 Email Correspondence re Commander Kumar documents, #3 Exhibit 3 - 06/26/2015 Correspondence re potential deposition witnesses, #4 Exhibit 4 - 11/04/2015 Email Correspondence re depositions in India, #5 Exhibit 5 - 11/20/2015 Email Correspondence re Rule 30(b)(6) deposition, #6 Exhibit 6 - 11/23/2015 Email Correspondence re Rule 30(b)(6) deposition) (Richmond, Rick)
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Filing 257
Brief in Support of #256 Motion to Compel Documents and a Continued Rule 30(b)(6) Deposition by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 256
Motion to Compel Documents and a Continued Rule 30(b)(6) Deposition by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 11/30/2015. (Richmond, Rick)
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Filing 255
Transcript of Telephonic Motion Hearing, held 11/20/15 before Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (jat)
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Filing 254
Declaration of Andrew Sullivan filed by Epic Systems Corporation re: #245 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Epic's Second Set of Requests for Production to TCS America, #2 Exhibit B - Epic's Second Set of Requests for Production to TCS India, #3 Exhibit C - Sept. 17, 2015 Letter re production of a report summarizing an investigation, #4 Exhibit D - Sept. 18, 2015 Letter in response to Sept. 17, 2015 Letter re production of a report summarizing an investigation) (Morrison, Kelly) Modified on 11/20/2015. (lak)
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Filing 253
Exhibit to #224 Brief in Support filed by Epic Systems Corporation, #212 Brief in Support filed by Epic Systems Corporation. (Table of Contents) (Morrison, Kelly) .
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Filing 252
ORDER granting #163 Motion to Compel. Defendants Tata Consultancy Services Limited and Tata America International Corporation is ordered to produce the requested documents on or before December 14, 2015, and produce a person for a 30(b)(6) deposition by the week of December 21, 2015. Signed by District Judge William M. Conley on 11/20/2015. (voc)
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Filing 251
** TEXT ONLY ORDER **During a telephonic hearing, the court set and extended the following deadlines and dates: (1) On December 4, 2015, at 9:00 AM, the court will hold an in-person hearing on plaintiff Epic's most recent motion to compel, dkt. #245 . Each side should have an employee or employees present who are familiar with that client's discovery efforts to date, as well as how relevant documents are generally maintained and searched by the client. (2) Plaintiff's response to defendants' motion for summary judgment, dkt. #197 , is now due January 15, 2016, and defendants' reply is due January 25, 2016. Signed by District Judge William M. Conley on 11/20/2015. (arw)
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Minute Entry for proceedings held before District Judge William M. Conley: Telephone Motion Hearing held on 11/20/2015 re #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita filed by Epic Systems Corporation [:30] (Court Reporter LS.) (mfh)
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Set Deadlines and Hearings re: #245 Motion to Compel Discovery Regarding TCS Investigations by Plaintiff Epic Systems Corporation. In-Person Motion Hearing set for 12/4/2015 at 9:00 AM before District Judge William M. Conley. (arw)
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Reset Briefing Deadlines re: #197 MOTION FOR PARTIAL SUMMARY JUDGMENT by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 1/15/2016. Brief in Reply due 1/25/2016. (arw)
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Filing 250
Redaction to #247 and #248 Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Declaration of Andrew Sullivan, #2 Exhibit 2 - 05/27/2015 TCS India's Responses and Objections to Plaintiff's First Set of Interrogatories, #3 Exhibit 3 - 05/27/2015 TCS America's Responses and Objections to Plaintiff's First Set of Interrogatories, #4 Exhibit 4 - 12/23/2014 Epic's First set of Expedited Discovery Requests to TCS India and TCS America, #5 Exhibit 5 - Deposition Exhibit 39, #6 Exhibit 6 - Deposition Exhibit 395, #7 Exhibit 7 - Deposition Exhibit 396, #8 Exhibit 8 - Deposition Exhibit 397, #9 Exhibit 9 - 07/25/2015 Letter from TCS to Epic, #10 Exhibit 10 - Deposition Exhibit 79, #11 Exhibit 11 - Deposition Exhibit 81, #12 Exhibit 12 - Deposition Exhibit 77, #13 Exhibit 13 - Deposition Exhibit 82, #14 Exhibit 14 - Deposition Exhibit 87, #15 Exhibit 15 - Document bates stamped TCS00020082 through TCS00020093, #16 Exhibit 16 - Document bates stamped TCS00020128 through TCS00020132, #17 Exhibit 17 - Document bates stamped TCS00020133 through TCS00020140, #18 Exhibit 18 - Deposition Exhibit 321, #19 Exhibit 19 - Deposition Exhibit 321A, #20 Exhibit 20 - Document bates stamped TCS00020216 through TCS00020219, #21 Exhibit 21 - 09/17/2015 Letter regarding scope of TCS's search for documents responsive to Epic's first and second sets of document requests, #22 Exhibit 22 - 10/23/2015 Defendants' Partial Privilege Log 23 - 10/29/2015 Epic's Notice of Rule 30(b)(6) Deposition to, #23 Exhibit 23 - 10/29/2015 Epic's Notice of Rule 30(b)(6) Deposition to Defendants Along With a Rule 34 Request for Documents, #24 Exhibit 24 - 10/29/2015 Epic's Notice of Deposition of Pushpa Hegde, #25 Exhibit 25 - 11/03/2015 Email regarding TCS's document collection and internal investigation, #26 Exhibit 26 - 11/03/2015 Email re TCS document production) (Richmond, Rick) Modified on 11/20/2015: Corrected docketing event. (lak)
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Filing 249
Redaction to #246 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 11/20/2015: Corrected docketing event. (lak)
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Filing 248
Exhibit to #247 Declaration filed by Epic Systems Corporation. Exhibit 17 - Document bates stamped TCS00020133 through TCS00020140, (Sealed Document) (Attachments: #1 Exhibit 18 - Deposition Exhibit 321, #2 Exhibit 19 - Deposition Exhibit 321A, #3 Exhibit 20 - Document bates stamped TCS00020216 through TCS00020219, #4 Exhibit 21 - 09/17/2015 Letter regarding scope of TCS's search for documents responsive to Epic's first and second sets of document requests, #5 Exhibit 22 - 10/23/2015 Defendants' Partial Privilege Log, #6 Exhibit 23 - 10/29/2015 Epic's Notice of Rule 30(b)(6) Deposition to Defendants Along With a Rule 34 Request for Documents, #7 Exhibit 24 - 10/29/2015 Epic's Notice of Deposition of Pushpa Hegde, #8 Exhibit 25 - 11/03/2015 Email regarding TCS's document collection and internal investigation, #9 Exhibit 26 - 11/03/2015 Email re TCS document production) (Richmond, Rick) Modified on 11/20/2015. (lak)
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Filing 247
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #245 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit 1 - Declaration of Andrew Sullivan (Also see #254 .), #2 Exhibit 2 - 05/27/2015 TCS India's Responses and Objections to Plaintiff's First Set of Interrogatories, #3 Exhibit 3 - 05/27/2015 TCS America's Responses and Objections to Plaintiff's First Set of Interrogatories, #4 Exhibit 4 - 12/23/2014 Epic's First set of Expedited Discovery Requests to TCS India and TCS America, #5 Exhibit 5 - Deposition Exhibit 39, #6 Exhibit 6 - Deposition Exhibit 395, #7 Exhibit 7 - Deposition Exhibit 396, #8 Exhibit 8 - Deposition Exhibit 397, #9 Exhibit 9 - 07/25/2015 Letter from TCS to Epic, #10 Exhibit 10 - Deposition Exhibit 79, #11 Exhibit 11 - Deposition Exhibit 81, #12 Exhibit 12 - Deposition Exhibit 77, #13 Exhibit 13 - Deposition Exhibit 82, #14 Exhibit 14 - Deposition Exhibit 87, #15 Exhibit 15 - Document bates stamped TCS00020082 through TCS00020093, #16 Exhibit 16 - Document bates stamped TCS00020128 through TCS00020132) (Richmond, Rick) Modified on 11/20/2015. (lak)
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Filing 246
Brief in Support of #245 Motion to Compel Discovery Regarding TCS Investigations by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 245
Motion to Compel Discovery Regarding TCS Investigations by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 11/30/2015. (Richmond, Rick)
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Filing 244
** TEXT ONLY ORDER **ORDER granting #241 Motion to Reschedule Hearing on Motion to Compel Discovery. Telephone Motion Hearing re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents reset from 11/23/2015 to 11/20/2015 at 10:00 AM. Signed by District Judge William M. Conley on 11/18/2015. (arw)
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Filing 243
ORDER denying #43 Motion to Dismiss; granting #152 Motion for Leave to File Second Amended Complaint. Answer due 12/2/2015. Signed by District Judge William M. Conley on 11/18/2015. (arw)
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Reset Deadlines and Hearings re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents. Telephone Motion Hearing reset for 11/20/2015 at 10:00 AM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (arw)
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Filing 242
Declaration of Philip D. Robben in support of defendants' motion to reschedule the hearing on plaintiff's motion to compel discovery concerning Davita filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #241 Motion to Reschedule Hearing. (Robben, Philip)
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Filing 241
Motion to Reschedule November 23, 2015 Hearing on Plaintiff's Motion to Compel Discovery Concerning Davita by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Response due 11/24/2015. (Robben, Philip) Modified on 11/18/2015. (arw)
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Filing 240
Redaction to #236 - #237 Exhibits filed by Epic Systems Corporation. (Attachments: #1 Exhibit 82 - 08/27/2015 TCS Responses and Objections to Amended First Set of Requests for Admission, #2 Exhibit 83 - Deposition Exhibit 199, #3 Exhibit 84 - Deposition Exhibit 199A, #4 Exhibit 85 - Deposition Exhibit 094, #5 Exhibit 86 - Deposition Exhibit 272, #6 Exhibit 87 - Deposition Exhibit 095, #7 Exhibit 88 - Deposition Exhibit 273, #8 Exhibit 89 - Deposition Exhibit 274, #9 Exhibit 90 - Deposition Exhibit 170, #10 Exhibit 91 - Deposition Exhibit 173, #11 Exhibit 92 - Deposition Exhibit 276, #12 Exhibit 93 - 09/16/2015 Email re TCS Supplemental Production [TCS00017919-TCS00017924], #13 Exhibit 94 - 04/03/2015 Plaintiff Epic's Second Set of Requests for Production to TCS, #14 Exhibit 95 - 04/03/2015 Plaintiff Epic's Second Set of Requests for Production to Tata America, #15 Exhibit 96 - Document bates stamped EPIC008790 through EPIC0087905, #16 Exhibit 97 - Screenshot of Epic's Website re Departments and Ancillaries, #17 Exhibit 98 - Excerpts of Spreadsheet Produced by Epic, EPIC00000001A, #18 Exhibit 99 - 11/03/2015 TCS America Amended Responses and Objections to Epic's First Set of Requests for Admission, #19 Exhibit 100 - Document bates stamped EPIC0092511, #20 Exhibit 101 - Document bates stamped EPIC0095384) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 239
Redaction to #232 - #236 Exhibits filed by Epic Systems Corporation. Exhibit 41 - Deposition Exhibit 303 (Attachments: #1 Exhibit 42 - Deposition Exhibit 296, #2 Exhibit 43 - Deposition Exhibit 106, #3 Exhibit 44 - Deposition Exhibit 304, #4 Exhibit 45 - Screenshot of CSC Company Profile, #5 Exhibit 46 - Deposition Exhibit 112, #6 Exhibit 47 - Deposition Exhibit 113, #7 Exhibit 48 - Deposition Exhibit 119, #8 Exhibit 49 - 05/27/2015 TCS America's Response to Plaintiff Epic's First Set of Interrogatories, #9 Exhibit 50 - 05/27/2015 TCS India's Response to Plaintiff Epic's First Set of Interrogatories, #10 Exhibit 51 - Deposition Exhibit 397, #11 Exhibit 52 - Deposition Exhibit 115, #12 Exhibit 53 - Deposition Exhibit 129, #13 Exhibit 54 - Deposition Exhibit 116, #14 Exhibit 55 - Deposition Exhibit 305, #15 Exhibit 56 - Deposition Exhibit 307, #16 Exhibit 57 - Deposition Exhibit 308, #17 Exhibit 58 - Deposition Exhibit 309, #18 Exhibit 59 - Deposition Exhibit 128, #19 Exhibit 60 - Deposition Exhibit 118, #20 Exhibit 61 - Deposition Exhibit 121, #21 Exhibit 62 - Deposition Exhibit 120, #22 Exhibit 63 - Deposition Exhibit 122, #23 Exhibit 64 - Deposition Exhibit 123, #24 Exhibit 65 - Deposition Exhibit 124, #25 Exhibit 66 - Deposition Exhibit 125, #26 Exhibit 67 - Deposition Exhibit 402, #27 Exhibit 68 - Deposition Exhibit 058, #28 Exhibit 69 - Deposition Exhibit 204, #29 Exhibit 70 - Deposition Exhibit 205, #30 Exhibit 71 - Deposition Exhibit 206, #31 Exhibit 72 - Deposition Exhibit 207, #32 Exhibit 73 - Deposition Exhibit 208, #33 Exhibit 74 - Deposition Exhibit 211, #34 Exhibit 75 - Deposition Exhibit 213, #35 Exhibit 76 - Deposition Exhibit 215, #36 Exhibit 77 - Deposition Exhibit 196, #37 Exhibit 78 - Deposition Exhibit 197, #38 Exhibit 79 - Deposition Exhibit 217, #39 Exhibit 80 - Deposition Exhibit 218) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 238
Redaction to #226 - #232 Declaration of Rick Richmond, (Attachments: #1 Exhibit 1 - Declaration of Stirling Martin (11/16/2015), #2 Exhibit 2 - Screenshot of Epic's Webpage re Contact Information, #3 Exhibit 3 - Screenshot of NYS Department of State, Division of Corporations - Tata Consultancy, #4 Exhibit 4 - 06/29/2015 Defendants' Responses to Epic's First Set of Requests for Admission, #5 Exhibit 5 - Screenshot of NYS Department of State, Division of Corporations - Tata America, #6 Exhibit 6 - Screenshot of Wisconsin Department of Financial Institutions, #7 Exhibit 7 - Deposition Exhibit 069, #8 Exhibit 8 - Screenshot of Business Standard News Article, #9 Exhibit 9 - Screenshot of TCS Worldwide India Locations Pages Default, #10 Exhibit 10 - Deposition Exhibit 245, #11 Exhibit 11 - Deposition Exhibit 144, #12 Exhibit 12 - Deposition Exhibit 061, #13 Exhibit 13 - Screenshot of TCS List of Subsidiaries, #14 Exhibit 14 - Deposition Exhibit 005, #15 Exhibit 15 - Screenshot of Kaiser Permanente's Website, #16 Exhibit 16 - Screenshot of Davita's Webpage, #17 Exhibit 17 - Deposition Exhibit 169, #18 Exhibit 18 - Deposition Exhibit 209, #19 Exhibit 19 - Document bates stamped EPIC0095374-EPIC0095377, #20 Exhibit 20 - Deposition Exhibit 003, #21 Exhibit 21 - 08/27/2015 Tata America Responses and Objections to Second Set of Interrogatories, #22 Exhibit 22 - 08/27/2015 TCS Responses and Objections to Second Set of Interrogatories, #23 Exhibit 23 - 10/19/2015 TCS America Responses to Second Set of Requests for Admission, #24 Exhibit 24 - 10/19/2015 TCS India Responses to Second Set of Requests for Admission, #25 Exhibit 25 - 10/19/2015 TCS America Responses to Third Set of Interrogatories, #26 Exhibit 26 - 10/19/2015 TCS India Responses to Third Set of Interrogatories, #27 Exhibit 27 - Deposition Exhibit 008, #28 Exhibit 28 - Deposition Exhibit 172, #29 Exhibit 29 - Deposition Exhibit 004A, #30 Exhibit 30 - Deposition Exhibit 009, #31 Exhibit 31 - Deposition Exhibit 002, #32 Exhibit 32 - Deposition Exhibit 004, #33 Exhibit 33 - Deposition Exhibit 133, #34 Exhibit 34 - Deposition Exhibit 050, #35 Exhibit 35 - Deposition Exhibit 133A, #36 Exhibit 36 - Deposition Exhibit 141, #37 Exhibit 37 - Deposition Exhibit 143, #38 Exhibit 38 - Deposition Exhibit 1064, #39 Exhibit 39 - Deposition Exhibit 1024, #40 Exhibit 40 - Deposition Exhibit 153) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 237
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 90 - Deposition Exhibit 170. (Sealed Document) (Attachments: #1 Exhibit 91 - Deposition Exhibit 173, #2 Exhibit 92 - Deposition Exhibit 276, #3 Exhibit 93 - 09/16/2015 Email re TCS Supplemental Production [TCS00017919-TCS00017924], #4 Exhibit 94 - 04/03/2015 Plaintiff Epic's Second Set of Requests for Production to TCS, #5 Exhibit 95 - 04/03/2015 Plaintiff Epic's Second Set of Requests for Production to Tata America, #6 Exhibit 96 - Document bates stamped EPIC008790 through EPIC0087905, #7 Exhibit 97 - Screenshot of Epic's Website re Departments and Ancillaries, #8 Exhibit 98 - Excerpts of Spreadsheet Produced by Epic, EPIC00000001A, #9 Exhibit 99 - 11/03/2015 TCS America Amended Responses and Objections to Epic's First Set of Requests for Production, #10 Exhibit 100 - Document bates stamped EPIC0092511, #11 Exhibit 101 - Document bates stamped EPIC0095384) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 236
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 68 - Deposition Exhibit 058. (Sealed Document) (Attachments: #1 Exhibit 69 - Deposition Exhibit 204, #2 Exhibit 70 - Deposition Exhibit 205, #3 Exhibit 71 - Deposition Exhibit 206, #4 Exhibit 72 - Deposition Exhibit 207, #5 Exhibit 73 - Deposition Exhibit 208, #6 Exhibit 74 - Deposition Exhibit 211, #7 Exhibit 75 - Deposition Exhibit 213, #8 Exhibit 76 - Deposition Exhibit 215, #9 Exhibit 77 - Deposition Exhibit 196, #10 Exhibit 78 - Deposition Exhibit 197, #11 Exhibit 79 - Deposition Exhibit 217, #12 Exhibit 80 - Deposition Exhibit 218, #13 Exhibit 81 - Deposition Exhibit 219, #14 Exhibit 82 - 08/27/2015 TCS Responses and Objections to Amended First Set of Requests for Admission, #15 Exhibit 83 - Deposition Exhibit 199, #16 Exhibit 84 - Deposition Exhibit 199A, #17 Exhibit 85 - Deposition Exhibit 094, #18 Exhibit 86 - Deposition Exhibit 272, #19 Exhibit 87 - Deposition Exhibit 095, #20 Exhibit 88 - Deposition Exhibit 273, #21 Exhibit 89 - Deposition Exhibit 274) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 235
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 67 - Deposition Exhibit 402. (Sealed Document) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 234
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 57 - Deposition Exhibit 308. (Sealed Document) (Attachments: #1 Exhibit 58 - Deposition Exhibit 309, #2 Exhibit 59 - Deposition Exhibit 128, #3 Exhibit 60 - Deposition Exhibit 118, #4 Exhibit 61 - Deposition Exhibit 121, #5 Exhibit 62 - Deposition Exhibit 120, #6 Exhibit 63 - Deposition Exhibit 122, #7 Exhibit 64 - Deposition Exhibit 123, #8 Exhibit 65 - Deposition Exhibit 124, #9 Exhibit 66 - Deposition Exhibit 125) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 233
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 42 - Deposition Exhibit 296. (Sealed Document) (Attachments: #1 Exhibit 43 - Deposition Exhibit 106, #2 Exhibit 44 - Deposition Exhibit 304, #3 Exhibit 45 - Screenshot of CSC Company Profile, #4 Exhibit 46 - Deposition Exhibit 112, #5 Exhibit 47 - Deposition Exhibit 113, #6 Exhibit 48 - Deposition Exhibit 119, #7 Exhibit 49 - 05/27/2015 TCS America's Response to Plaintiff Epic's First Set of Interrogatories, #8 Exhibit 50 - 05/27/2015 TCS India's Response to Plaintiff Epic's First Set of Interrogatories, #9 Exhibit 51 - Deposition Exhibit 397, #10 Exhibit 52 - Deposition Exhibit 115, #11 Exhibit 53 - Deposition Exhibit 129, #12 Exhibit 54 - Deposition Exhibit 116, #13 Exhibit 55 - Deposition Exhibit 305, #14 Exhibit 56 - Deposition Exhibit 307) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 232
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 32 - Deposition Exhibit 004. (Sealed Document) (Attachments: #1 Exhibit 33 - Deposition Exhibit 133, #2 Exhibit 34 - Deposition Exhibit 050, #3 Exhibit 35 - Deposition Exhibit 133A, #4 Exhibit 36 - Deposition Exhibit 141, #5 Exhibit 37 - Deposition Exhibit 143, #6 Exhibit 38 - Deposition Exhibit 1064, #7 Exhibit 39 - Deposition Exhibit 1024, #8 Exhibit 40 - Deposition Exhibit 153, #9 Exhibit 41 - Deposition Exhibit 303) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 231
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 29 - Deposition Exhibit 004A. (Sealed Document) (Attachments: #1 Exhibit 30 - Deposition Exhibit 009, #2 Exhibit 31 - Deposition Exhibit 002) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 230
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 18 - Deposition Exhibit 209. (Sealed Document) (Attachments: #1 Exhibit 19 - Document bates stamped EPIC0095374-EPIC0095377, #2 Exhibit 20 - Deposition Exhibit 003, #3 Exhibit 21 - 08/27/2015 Tata America Responses and Objections to Second Set of Interrogatories, #4 Exhibit 22 - 08/27/2015 TCS Responses and Objections to Second Set of Interrogatories, #5 Exhibit 23 - 10/19/2015 TCS America Responses to Second Set of Requests for Admission, #6 Exhibit 24 - 10/19/2015 TCS India Responses to Second Set of Requests for Admission, #7 Exhibit 25 - 10/19/2015 TCS America Responses to Third Set of Interrogatories, #8 Exhibit 26 - 10/19/2015 TCS India Responses to Third Set of Interrogatories, #9 Exhibit 27 - Deposition Exhibit 008, #10 Exhibit 28 - Deposition Exhibit 172) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 229
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 16 - Screenshot of Davita's Webpage. (Sealed Document) (Attachments: #1 Exhibit 17 - Deposition Exhibit 169) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 228
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 14 - Deposition Exhibit 005. (Sealed Document) (Attachments: #1 Exhibit 15 - Screenshot of Kaiser Permanente's Website) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 227
Exhibit to #226 Declaration filed by Epic Systems Corporation. Exhibit 11 - Deposition Exhibit 144. (Sealed Document) (Attachments: #1 Exhibit 12 - Deposition Exhibit 061, #2 Exhibit 13 - Screenshot of TCS List of Subsidiaries) (Richmond, Rick) Modified on 11/17/2015. (lak)
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Filing 226
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #195 Motion for Partial Summary Judgment (Sealed Document) (Attachments: #1 Exhibit 1 - Declaration of Stirling Martin (11/16/2015), #2 Exhibit 2 - Screenshot of Epic's Webpage re Contact Information, #3 Exhibit 3 - Screenshot of NYS Department of State, Division of Corporations - Tata Consultancy, #4 Exhibit 4 - 06/29/2015 Defendants' Responses to Epic's First Set of Requests for Admission, #5 Exhibit 5 - Screenshot of NYS Department of State, Division of Corporations - Tata America, #6 Exhibit 6 - Screenshot of Wisconsin Department of Financial Institutions, #7 Exhibit 7 - Deposition Exhibit 069, #8 Exhibit 8 - Screenshot of Business Standard News Article, #9 Exhibit 9 - Screenshot of TCS Worldwide India Locations Pages Default, #10 Exhibit 10 - Deposition Exhibit 245) (Richmond, Rick)
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Filing 225
Redaction to #213 Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 11/17/2015: Corrected docketing event. (lak)
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Filing 224
Redaction to #212 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 11/17/2015: Corrected docketing event. (lak)
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Filing 223
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 222
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 221
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 220
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 219
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 218
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 217
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 216
Disregard. To be refiled. Modified on 11/17/2015. (lak)
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Filing 215
Redaction to #214 Brief in Support of Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 214
Brief in Support of #197 Motion for Partial Summary Judgment by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Robben, Philip)
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Filing 213
Proposed Findings of Fact filed by Plaintiff Epic Systems Corporation re: #195 Motion for Partial Summary Judgment. (Sealed Document) (Richmond, Rick)
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Filing 212
Brief in Support of #195 Motion for Partial Summary Judgment by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 211
Redaction to #210 Proposed Findings of Fact, by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 11/17/2015. (lak)
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Filing 210
Proposed Findings of Fact filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment. (Sealed Document) (Robben, Philip) Modified on 11/17/2015. (lak)
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Filing 209
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 208
Redaction to #204 Declaration, by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Attachments: #1 Exhibit 1 - Slipsheet, #2 Exhibit 2 - Slipsheet, #3 Exhibit 3 - Slipsheet, #4 Exhibit 4 - Slipsheet, #5 Exhibit 5 - Slipsheet, #6 Exhibit 6 - Slipsheet, #7 Exhibit 7 - Slipsheet, #8 Exhibit 8 - Slipsheet, #9 Exhibit 9 - Slipsheet, #10 Exhibit 10 - Slipsheet, #11 Exhibit 11 - Slipsheet, #12 Exhibit 12 - Slipsheet, #13 Exhibit 13 - Slipsheet, #14 Exhibit 14 - Slipsheet, #15 Exhibit 15 - Slipsheet, #16 Exhibit 16 - Slipsheet, #17 Exhibit 17 - Slipsheet, #18 Exhibit 18 - Slipsheet, #19 Exhibit 19 - Slipsheet, #20 Exhibit 20 - Slipsheet, #21 Exhibit 21 - Slipsheet, #22 Exhibit 22 - Slipsheet, #23 Exhibit 23 - Slipsheet, #24 Exhibit 24 - Slipsheet, #25 Exhibit 25 - Slipsheet, #26 Exhibit 26 - Slipsheet, #27 Exhibit 27 - Slipsheet, #28 Exhibit 28 - Slipsheet, #29 Exhibit 29 - Slipsheet) (Robben, Philip) Modified on 11/17/2015. (lak)
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Filing 207
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 206
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 205
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 204
Declaration of Philip D. Robben in Support of Defendants' Motion for Partial Summary Judgment filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #197 Motion for Partial Summary Judgment, (Sealed Document) (Attachments: #1 Exhibit 1 - Martin Deposition Exhibit 1050, #2 Exhibit 2 - Dvorak Deposition Exhibit 1056, #3 Exhibit 3 - Guionnet Deposition Exhibit 4, #4 Exhibit 4 - 2011 Statement of Work, #5 Exhibit 5 - 2014 Statement of Work, #6 Exhibit 6 - 2015-06-29 TCS Responses to First Set of Requests for Admission, #7 Exhibit 7 - Muthuswami Deposition Exhibit 395, #8 Exhibit 8 - Dvorak Deposition Exhibit 1068, #9 Exhibit 9 - Martin Deposition Exhibit 1042, #10 Exhibit 10 - Dvorak Deposition Exhibit 1060, #11 Exhibit 11 - Dvorak Deposition Exhibit 1061, #12 Exhibit 12 - Dvorak Deposition Exhibit 1062, #13 Exhibit 13 - Dvorak Deposition Exhibit 1064, #14 Exhibit 14 - Dvorak Deposition Exhibit 1073, #15 Exhibit 15 - Dvorak Deposition Exhibit 1065, #16 Exhibit 16 - Martin Deposition Exhibit 1044, #17 Exhibit 17 - Rehm Deposition Exhibit 1027, #18 Exhibit 18 - Rehm Deposition Exhibit 1028, #19 Exhibit 19 - Rehm Deposition Exhibit 1030, #20 Exhibit 20 - Rehm Deposition Exhibit 1033, #21 Exhibit 21 - 2015-07-24 Epic's Responses to TCS's Second Set of Interrogatories, #22 Exhibit 22 - 2015-06-11 Epic's Amended Objections and Responses to Defendants' First Set of Interrogatories, #23 Exhibit 23 - Gupta Deposition Exhibit 185, #24 Exhibit 24 - Muthuswami Deposition Exhibit 159A, #25 Exhibit 25 - 2015-05-27 TCS India Responses & Objections to Epic's First Set of Interrogatories, #26 Exhibit 26 - Rehm Deposition Exhibit 1031, #27 Exhibit 27 - Buchanan Deposition Exhibit 1003, #28 Exhibit 28 - Buchanan Deposition Exhibit 1010, #29 Exhibit 29 - Dvorak Deposition Exhibit 1063) (Robben, Philip) Modified on 11/17/2015. (lak)
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Filing 203
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 202
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 201
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 200
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 199
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 198
Disregard. To be refiled. (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 197
MOTION FOR PARTIAL SUMMARY JUDGMENT by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 12/16/2015. Brief in Reply due 12/31/2015. (Robben, Philip)
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Filing 196
Disregard. See #204 . (Sealed Document) Modified on 11/17/2015. (lak)
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Filing 195
MOTION FOR PARTIAL SUMMARY JUDGMENT by Plaintiff Epic Systems Corporation. Brief in Opposition due 12/16/2015. Brief in Reply due 12/31/2015. (Richmond, Rick)
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Filing 194
Disregard. See #197 . Modified on 11/17/2015. (lak)
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Filing 193
Redaction to #192 Declaration of Philip D. Robben in Opposition to Plaintiff's Motion to Compel Rule 30(B)(6) Deposition Testimony and Production of Documents re: Davita filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Slipsheet, #2 Exhibit B - Slipsheet, #3 Exhibit C - Slipsheet, #4 Exhibit D - Slipsheet, #5 Exhibit E - Slipsheet) (Robben, Philip) Modified on 11/16/2015: Corrected docketing event, etc. (lak)
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Filing 192
Declaration of Philip D. Robben in Opposition to Plaintiff's Motion to Compel Rule 30(B)(6) Deposition Testimony and Production of Documents re Davita filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #163 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Deposition Exhibit 4 - MSA, #2 Exhibit B - 2011 Statement of Work, #3 Exhibit C - Deposition Exhibit 401, #4 Exhibit D - 2014 Statement of Work, #5 Exhibit E - Deposition Exhibit 395) (Robben, Philip) Modified on 11/16/2015: Clarified exhibit descriptions. (lak)
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Filing 191
Redaction to #190 Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Byroade, Melissa) Modified on 11/16/2015: Corrected docketing event. (lak)
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Filing 190
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #163 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (Byroade, Melissa)
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Filing 189
Expert Report of Erik Laykin dated November 9, 2015 by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Sealed Document) (Attachments: #1 Exhibit A--Curriculum Vitae of Erik Laykin, #2 Exhibit B--Documents Relied Upon by Laykin, #3 Exhibit C--Representative Exemplars of 7,618 PNG Images) (Vergeront, Meg)
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Filing 188
Deposition of Suresh Muthuswami taken on November 9, 2015. (Sealed Document) (Richmond, Rick)
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Filing 187
Deposition of Carl Dvorak taken on October 29, 2015. (Sealed Document) (Richmond, Rick)
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Filing 186
Deposition of Stirling Martin taken on October 28, 2015. (Sealed Document) (Richmond, Rick)
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Filing 185
Deposition of Brett Rehm taken on October 22, 2015. (Sealed Document) (Richmond, Rick)
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Filing 184
Deposition of Michael Buchanan taken on October 21, 2015. (Sealed Document) (Richmond, Rick)
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Filing 183
Deposition of Vikram Vadamalai taken on September 15, 2015. (Sealed Document) (Richmond, Rick)
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Filing 182
Deposition of Spikanth (Skrikanth) (Srikanth) Telkapalli taken on September 14, 2015. (Sealed Document) (Richmond, Rick) Modified on 11/12/2015: Name is spelled different ways. (lak)
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Filing 181
Deposition of Nazia Khader taken on September 14, 2015. (Sealed Document) (Richmond, Rick)
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Filing 180
Deposition of Philippe Guionnet taken on October 7, 2015. (Sealed Document) (Richmond, Rick)
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Filing 179
Deposition of Philippe Guionnet taken on October 5, 2015. (Sealed Document) (Richmond, Rick)
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Filing 178
Deposition of Philippe Guionnet taken on August 12, 2015. (Sealed Document) (Richmond, Rick)
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Filing 177
Deposition of Philippe Guionnet taken on August 6, 2015. (Sealed Document) (Richmond, Rick)
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Filing 176
Deposition of Philippe Guionnet taken on August 5, 2015. (Sealed Document) (Richmond, Rick)
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Set Deadlines and Hearings re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re: DaVita by Plaintiff Epic Systems Corporation. Telephone Motion Hearing set for 11/18/2015 at 3:00 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (arw/slc)
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Reset Deadlines and Hearings re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re: DaVita by Plaintiff Epic Systems Corporation. Telephone Motion Hearing reset for 11/23/2015 at 1:00 PM before District Judge William M. Conley. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5087. (arw)
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Filing 175
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15f - Deposition Exhibit 169 Continued) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 174
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15e - Deposition Exhibit 169 Continued) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 173
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15d - Deposition Exhibit 169 Continued) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 172
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15c - Deposition Exhibit 169 Continued) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 171
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15b - Deposition Exhibit 169 Continued) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 170
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 15a - Deposition Exhibit 169) (Richmond, Rick) Modified on 11/9/2015: Added exhibit description. (lak)
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Filing 169
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 21 - Deposition Exhibit 156, #2 Exhibit 22 - Deposition Exhibit 159A, #3 Exhibit 23 - Deposition Exhibit 26, #4 Exhibit 24 - Deposition Exhibit 250, #5 Exhibit 25 - Deposition Exhibit 65, #6 Exhibit 26 - Deposition Exhibit 66, #7 Exhibit 31 - Defendant's Responses and Objections to Fifth Set of Requests for Production, #8 Exhibit 32 - Tata America International Corporation's Responses and Objections to First Set of Interrogatories, #9 Exhibit 33 - Tata Consultancy Services Limited's Responses and Objections to First Set of Interrogatories) (Richmond, Rick) Modified on 11/9/2015: Added exhibit descriptions. (lak)
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Filing 168
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 11 - Deposition Exhibit 2, #2 Exhibit 12 - Deposition Exhibit 339, #3 Exhibit 13 - Deposition Exhibit 39, #4 Exhibit 14 - Deposition Exhibit 10, #5 Exhibit 16 - Deposition Exhibit 149, #6 Exhibit 17 - Excerpt of a Spreadsheet, #7 Exhibit 18 - Excerpt of a Spreadsheet, #8 Exhibit 19 - Screenshot, #9 Exhibit 20 - Deposition Exhibit 61) (Richmond, Rick) Modified on 11/9/2015: Added exhibit descriptions. (lak)
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Filing 167
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita, (Sealed Document) (Attachments: #1 Exhibit 1 - Deposition Exhibit 303, #2 Exhibit 2 - Tata America International Corporation's Responses and Objections to First Set of Interrogatories, #3 Exhibit 3 - Tata Consultancy Services Limited's Responses and Objections to First Set of Interrogatories, #4 Exhibit 4 - Deposition Exhibit 8, #5 Exhibit 6 - Deposition Exhibit 14, #6 Exhibit 8 - Report Dated 9/12/2014, #7 Exhibit 9 - Organization Chart, #8 Exhibit 10 - Deposition Exhibit 1) (Richmond, Rick) Modified on 11/9/2015: Added exhibit descriptions. (lak)
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Filing 166
Brief in Support of #163 Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 165
Redaction to Declarations #167 - #175 filed by Plaintiff Epic Systems Corporation, (Attachments: #1 Exhibit 1 - Deposition Exhibit 303, #2 Exhibit 2 - Tata America International Corporation's Responses and Objections to First Set of Interrogatories, #3 Exhibit 3 - Tata Consultancy Services Limited's Responses and Objections to First Set of Interrogatories, #4 Exhibit 4 - Deposition Exhibit 8, #5 Exhibit 5 - Letter Dated 6/26/2015, #6 Exhibit 6 - Deposition Exhibit 14, #7 Exhibit 7 - E-mail Dated 10/27/2015, #8 Exhibit 8 - Report Dated 9/12/2014, #9 Exhibit 9 - Organization Chart, #10 Exhibit 10 - Deposition Exhibit 1, #11 Exhibit 11 - Deposition Exhibit 2, #12 Exhibit 12 - Deposition Exhibit 339, #13 Exhibit 13 - Deposition Exhibit 39, #14 Exhibit 14 - Deposition Exhibit 10, #15 Exhibit 15 - Deposition Exhibit 169, #16 Exhibit 16 - Deposition Exhibit 149, #17 Exhibit 17 - Excerpt of a Spreadsheet, #18 Exhibit 18 - Excerpt of a Spreadsheet, #19 Exhibit 19 - Screenshot, #20 Exhibit 20 - Deposition Exhibit 61, #21 Exhibit 21 - Deposition Exhibit 156, #22 Exhibit 22 - Deposition Exhibit 159A, #23 Exhibit 23 - Deposition Exhibit 26, #24 Exhibit 24 - Deposition Exhibit 250, #25 Exhibit 25 - Deposition Exhibit 65, #26 Exhibit 26 - Deposition Exhibit 66, #27 Exhibit 27 - Notice of Deposition, #28 Exhibit 28 - E-mail Dated 10/10/2015, #29 Exhibit 29 - Letter Dated 7/8/2015, #30 Exhibit 30 - E-mail Dated 10/13/2015, #31 Exhibit 31 - Defendant's Responses and Objections to Fifth Set of Requests for Production, #32 Exhibit 32 - Tata America International Corporation's Responses and Objections to First Set of Interrogatories, #33 Exhibit 33 - Tata Consultancy Services Limited's Responses and Objections to First Set of Interrogatories) (Richmond, Rick) Modified on 11/9/2015: Corrected docketing event; added exhibit descriptions. (lak)
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Filing 164
Redaction to #166 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 11/8/2015: Corrected docket event; linked to the sealed document. (lak)
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Filing 163
Motion to Compel Rule 30(b)(6) Deposition Testimony and Production of Documents re DaVita by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 11/13/2015. (Richmond, Rick)
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Filing 162
Deposition of Phillipe Guionnet taken on October 9, 2015. (Sealed Document) (Richmond, Rick)
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Filing 161
Deposition of Venu Medikondra taken on September 25, 2015. (Sealed Document) (Richmond, Rick)
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Filing 160
Deposition of Ramareddy Badam taken on September 17, 2015. (Sealed Document) (Richmond, Rick)
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Filing 159
Deposition of Venugopal Reddy taken on September 16, 2015. (Sealed Document) (Richmond, Rick)
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Filing 158
Deposition of Suresh Muthuswami taken on September 1, 2015. (Sealed Document) (Richmond, Rick)
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Filing 157
Deposition of Philippe Guionnet taken on August 10, 2015. (Sealed Document) (Richmond, Rick)
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Filing 156
Deposition of Philippe Guionnet taken on August 4, 2015. (Sealed Document) (Richmond, Rick)
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Filing 155
Transcript of Telephonic Motion Hearing, held 10/28/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Filing 154
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #152 Motion for Leave to File, (Attachments: #1 Exhibit 1-Stipulation Regarding Second Amended Complaint, #2 Exhibit 2-[Proposed] Second Amended Complaint, #3 Exhibit 3-[Proposed] Second Amended Complaint (Redline), #4 Exhibit 4-10/15 Email From K. Morrison, #5 Exhibit 5-10/20 ECF Notice) (Richmond, Rick)
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Filing 153
Brief in Support of #152 Motion for Leave to File Second Amended Complaint by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 152
Motion for Leave to File Second Amended Complaint by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 151
** TEXT ONLY ORDER **On October 28, 2015, the court held a telephonic hearing to follow up on plaintiff's motion to compel disclosure of a document for which privilege was claimed (dkt. #107 ) and to obtain input and to rule on plaintiff's motion to compel three specific types of discovery (dkt. #135 ). As discussed at the hearing, the court denied plaintiff's motion to compel disclosure of the document for which privilege was claimed: the documents submitted in camera by defendant establish that this document qualifies as attorney work product under F.R. Civ. Pro. 26(b)(3)(A). As further discussed at the hearing, the court granted in all parts plaintiff's motion to compel complete discovery on the three specified topics (dkt. #135 ). It is defendant's responsibility proactively and without qualification to employ all means and methods at its disposal to ensure that it actually has uncovered and disclosed all information responsive to plaintiffs' requests in its motion. Signed by Magistrate Judge Stephen L. Crocker on 10/28/2015. (kwf)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 10/28/2015 re #135 Motion to Compel Documents Regarding TCS'S Electronic Health Records Products and Evidence of Illicit Downloads filed by Epic Systems Corporation [:25] (Court Reporter ls.) (skv)
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Filing 150
Redaction to #149 Declaration by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Attachments: #1 Exhibit A--true and correct copy of June 29, 2015 hearing transcript, #2 Exhibit B--true and correct copy of the July 9, 2015 letter Epic sent to TCS, #3 Exhibit C--true and correct copy of the July 22, 2015 letter TCS sent to Epic, #4 Exhibit D--true and correct copy of Epic's September 16, 2015 letter requesting additional documents related to Med Mantra, #5 Exhibit E--true and correct copy of the October 6, 2015 email from TCS to Epic, #6 Exhibit F--true and correct copy of the notification received that Epic's counsel had downloaded the material, #7 Exhibit G--true and correct copy of the October 14, 2015 letter from Epic to TCS, #8 Exhibit H--true and correct copy of the October 15, 2015 email from TCS to Epic) (Neider, Barbara)
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Filing 149
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #135 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A--true and correct copy of June 29, 2015 hearing transcript, #2 Exhibit B--true and correct copy of the July 9, 2015 letter Epic sent to TCS, #3 Exhibit C--true and correct copy of the July 22, 2015 letter TCS sent to Epic, #4 Exhibit D--true and correct copy of Epic's September 16, 2015 letter requesting additional documents related to Med Mantra, #5 Exhibit E--true and correct copy of the October 6, 2015 email from TCS to Epic, #6 Exhibit F--true and correct copy of the notification received that Epic's counsel had downloaded the material, #7 Exhibit G--true and correct copy of the October 14, 2015 letter from Epic to TCS, #8 Exhibit H--true and correct copy of the October 15, 2015 email from TCS to Epic) (Neider, Barbara)
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Filing 148
Redaction to #147 Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 147
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #135 Motion to Compel, filed by Epic Systems Corporation. (Sealed Document) (Neider, Barbara)
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Filing 146
In Camera Submission - Declaration of Byroade in Further Opposition to Plaintiff's Motion to Compel Production of Document by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Ex Parte Document) (Attachments: #1 Exhibit 1 - Email to Mukherji, #2 Exhibit 2 - Email to Verghese, #3 Exhibit 3 - Email to Nambiar) (Neider, Barbara)
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Filing 145
Disregard. See #146 . (Ex Parte Document) Modified on 10/22/2015 (voc).
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Filing 144
In Camera Submission - Declaration of Vinod Verghese by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Ex Parte Document) (Neider, Barbara) Modified on 10/23/2015. (lak)
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Filing 143
Transcript of Telephone Motion Hearing, held 10/20/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Filing 142
** TEXT ONLY ORDER **On October 20, 2015, the court held a telephonic hearing on three pending discovery motions, dkts. #93 , #107 and #112 . The record of this hearing will speak for itself, but by way of an overview, the court extended the deadline to file summary judgment motions to November 16, 2015 in order to provide the parties a bit more breathing room for the parties to complete the discovery that they deem important to motions practice. The court granted in principle the remaining portion of the motion docketed as #93 : defendant is to produce the requested records for witnesses Kumar and Rathina by November 3, 2015, and the two depositions presumptively will occur by November 11, 2015 unless the parties agree otherwise. The location/medium of these depositions remains open to discussion between the parties. The court stayed its ruling on the motion docketed as #107 ; defendant has until October 22, 2015 to submit in camera the foundational evidence that actually establishes that the document qualifies for protection under the attorney-client privilege. The court granted the motion docketed as #112 in principle but left it to the parties in the first instance to negotiate the date and location of the follow-up 30(b)(6) deposition. At this point, no costs on these motions will be shifted in either direction. Signed by Magistrate Judge Stephen L. Crocker on 10/20/2015. (arw)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 10/20/2015 re #107 Motion to Compel Production of Document Over Which Defendants Have Improperly Asserted Privilege filed by Epic Systems Corporation [:50] (Court Reporter ls.) (skv)
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Reset Deadlines: Dispositive Motions due 11/16/2015. (arw)
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Filing 141
** TEXT ONLY ORDER **ORDER granting #140 Motion to Admit Alison Leigh MacGregor Pro Hac Vice. Signed by Magistrate Judge Peter A. Oppeneer on 10/19/2015. (lak)
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Filing 140
Motion to Admit Alison Leigh MacGregor Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt number 0758-1666663.) by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. (MacGregor, Alison)
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Set Deadlines and Hearings re: #135 Motion to Compel Documents Regarding TCS' Electronic Health Records Products and Evidence of Illicit Downloads. Telephone Motion Hearing set for 10/28/2015 at 2:30 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (arw)
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Filing 139
Exhibit to #138 Declaration, filed by Epic Systems Corporation. Exhibit 1 - TCS America's Responses to 1st Set of Interrogatories. (Sealed Document) (Attachments: #1 Exhibit 3 - Document Bearing the BATS number TCS17919-17926) (Richmond, Rick) Modified on 10/19/2015: Linked to the pending motion. (lak)
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Filing 138
Declaration of AnnaMarie Van Hoesen filed by Plaintiff Epic Systems Corporation in Support re: #135 Motion to Compel, (Attachments: #1 Exhibit 1 - TCS America's Responses to 1st Set of Interrogatories (Filed Under Seal), #2 Exhibit 2 - October 6, 2015 Email from TCS Counsel, #3 Exhibit 3 - Document Bearing the BATS Number TCS17919-17926 (Filed Under Seal), #4 Exhibit 4 - June 29, 2015 Hearing Transcript Excerpts) (Richmond, Rick) Modified on 10/19/2015. (lak)
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Filing 137
Redaction to #136 Brief in Support by Plaintiff Epic Systems Corporation (Richmond, Rick)
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Filing 136
Brief in Support of #135 Motion to Compel, by Plaintiff Epic Systems Corporation (Sealed Document) (Richmond, Rick)
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Filing 135
Motion to Compel Documents Regarding TCS'S Electronic Health Records Products and Evidence of Illicit Downloads by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 10/23/2015. (Richmond, Rick)
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Filing 134
Exhibits re: #93 Motion to Compel, filed by Epic Systems Corporation. Exhibit 1 - Exhibit 321 in the Deposition of Philippe Guionnet (Sealed Document) (Attachments: #1 Exhibit 2 - Exhibit 321-A in the Deposition of Philippe Guionnet, #2 Exhibit 3 - Exhibit 361 in the Deposition of Philippe Guionnet, #3 Exhibit 4 - Exhibit 362 in the Deposition of Philippe Guionnet, #4 Exhibit 5 - Exhibit 363 in the Deposition of Philippe Guionnet, #5 Exhibit 6 - Exhibit 364 in the Deposition of Philippe Guionnet, #6 Exhibit 7 - Exhibit 365 in the Deposition of Philippe Guionnet, #7 Exhibit 8 - Exhibit 366 in the Deposition of Philippe Guionnet, #8 Exhibit 9 - Exhibit 367 in the Deposition of Philippe Guionnet, #9 Exhibit 10 - Exhibit 368 in the Deposition of Philippe Guionnet, #10 Exhibit 11 - Exhibit 369 in the Deposition of Philippe Guionnet, #11 Exhibit 12 - Exhibit 370 in the Deposition of Philippe Guionnet, #12 Exhibit 13 - Exhibit 371 in the Deposition of Philippe Guionnet, #13 Exhibit 14 - Exhibit 372 in the Deposition of Philippe Guionnet, #14 Exhibit 15 - Exhibit 373 in the Deposition of Philippe Guionnet, #15 Exhibit 16 - Exhibit 374 in the Deposition of Philippe Guionnet, #16 Exhibit 17 - Exhibit 375 in the Deposition of Philippe Guionnet, #17 Exhibit 18 - Exhibit 376 in the Deposition of Philippe Guionnet, #18 Exhibit 19 - Exhibit 377 in the Deposition of Philippe Guionnet, #19 Exhibit 20 - Exhibit 378 in the Deposition of Philippe Guionnet, #20 Exhibit 21 - Exhibit 379 in the Deposition of Philippe Guionnet, #21 Exhibit 22 - Exhibit 380 in the Deposition of Philippe Guionnet, #22 Exhibit 23 - Exhibit 381 in the Deposition of Philippe Guionnet, #23 Exhibit 24 - Exhibit 382 in the Deposition of Philippe Guionnet, #24 Exhibit 25 - Exhibit 383 in the Deposition of Philippe Guionnet, #25 Exhibit 26 - Exhibit 384 in the Deposition of Philippe Guionnet, #26 Exhibit 27 - Exhibit 385 in the Deposition of Philippe Guionnet, #27 Exhibit 28 - Exhibit 386 in the Deposition of Philippe Guionnet, #28 Exhibit 29 - Exhibit 389 in the Deposition of Philippe Guionnet) (Richmond, Rick) Modified on 10/19/2015. (lak)
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Filing 133
Redaction to #134 Exhibits, (Attachments: #1 Exhibit 1 - Exhibit 321 in the Deposition of Philippe Guionnet (Filed under Seal), #2 Exhibit 2 - Exhibit 321-A in the Deposition of Philippe Guionnet (Filed under Seal), #3 Exhibit 3 - Exhibit 361 in the Deposition of Philippe Guionnet (Filed under Seal), #4 Exhibit 4 - Exhibit 362 in the Deposition of Philippe Guionnet (Filed under Seal), #5 Exhibit 5 - Exhibit 363 in the Deposition of Philippe Guionnet (Filed under Seal), #6 Exhibit 6 - Exhibit 364 in the Deposition of Philippe Guionnet (Filed under Seal), #7 Exhibit 7 - Exhibit 365 in the Deposition of Philippe Guionnet (Filed under Seal), #8 Exhibit 8 - Exhibit 366 in the Deposition of Philippe Guionnet (Filed under Seal), #9 Exhibit 9 - Exhibit 367 in the Deposition of Philippe Guionnet (Filed under Seal), #10 Exhibit 10 - Exhibit 368 in the Deposition of Philippe Guionnet (Filed under Seal), #11 Exhibit 11 - Exhibit 369 in the Deposition of Philippe Guionnet (Filed under Seal), #12 Exhibit 12 - Exhibit 370 in the Deposition of Philippe Guionnet (Filed under Seal), #13 Exhibit 13 - Exhibit 371 in the Deposition of Philippe Guionnet (Filed under Seal), #14 Exhibit 14 - Exhibit 372 in the Deposition of Philippe Guionnet (Filed under Seal), #15 Exhibit 15 - Exhibit 373 in the Deposition of Philippe Guionnet (Filed under Seal), #16 Exhibit 16 - Exhibit 374 in the Deposition of Philippe Guionnet (Filed under Seal), #17 Exhibit 17 - Exhibit 375 in the Deposition of Philippe Guionnet (Filed under Seal), #18 Exhibit 18 - Exhibit 376 in the Deposition of Philippe Guionnet (Filed under Seal), #19 Exhibit 19 - Exhibit 377 in the Deposition of Philippe Guionnet (Filed under Seal), #20 Exhibit 20 - Exhibit 378 in the Deposition of Philippe Guionnet (Filed under Seal), #21 Exhibit 21 - Exhibit 379 in the Deposition of Philippe Guionnet (Filed under Seal), #22 Exhibit 22 - Exhibit 380 in the Deposition of Philippe Guionnet (Filed under Seal), #23 Exhibit 23 - Exhibit 381 in the Deposition of Philippe Guionnet (Filed under Seal), #24 Exhibit 24 - Exhibit 382 in the Deposition of Philippe Guionnet (Filed under Seal), #25 Exhibit 25 - Exhibit 383 in the Deposition of Philippe Guionnet (Filed under Seal), #26 Exhibit 26 - Exhibit 384 in the Deposition of Philippe Guionnet (Filed under Seal), #27 Exhibit 27 - Exhibit 385 in the Deposition of Philippe Guionnet (Filed under Seal), #28 Exhibit 28 - Exhibit 386 in the Deposition of Philippe Guionnet (Filed under Seal), #29 Exhibit 29 - Exhibit 389 in the Deposition of Philippe Guionnet (Filed under Seal)) (Richmond, Rick) Modified on 10/19/2015. (lak)
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Filing 132
Deposition of Aswin Kumar Anandhan taken on September 30, 2015. (Sealed Document) (Richmond, Rick)
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Filing 131
Deposition of Vijayasiradhi Badipatla taken on September 18, 2015. (Sealed Document) (Richmond, Rick)
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Filing 130
Deposition of Mukesh Kumar taken on September 15, 2015. (Sealed Document) (Richmond, Rick)
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Filing 129
Deposition of Anmol Gupta taken on September 10, 2015. (Sealed Document) (Richmond, Rick)
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Filing 128
Deposition of Ramesh Gajaram taken on August 13, 2015. (Sealed Document) (Richmond, Rick)
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Filing 127
Deposition of David G. Jones taken on September 22, 2015. (Sealed Document) (Richmond, Rick)
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Filing 126
Deposition of Syama Sundar taken on September 24, 2015. (Sealed Document) (Richmond, Rick)
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Filing 125
Deposition of Syama Sundar taken on August 28, 2015. (Sealed Document) (Richmond, Rick)
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Filing 124
Deposition of Philippe Guionnet taken on October 9, 2015 (Rough Transcript). (Sealed Document) (Richmond, Rick)
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Filing 123
** TEXT ONLY ORDER **ORDER granting #121 plaintiff's request to add the "reserved issues" discovery dispute to the agenda of the October 20, 2015 telephonic motion hearing. Signed by Magistrate Judge Stephen L. Crocker on 10/16/2015. (arw)
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Filing 122
Declaration of Melissa Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited Regarding Defendants' Efforts to Resolve Plaintiff's re: #112 Motion to Compel (Attachments: #1 Exhibit A- 10-2015 Emails between Epic and TCS counsel) (Neider, Barbara)
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Filing 121
Motion for Hearing on Reserved Issues from Motion to Compel by Plaintiff Epic Systems Corporation. Response due 10/23/2015. (Richmond, Rick)
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Filing 120
Redaction to #119 Declaration of Melissa Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A - Excerpts of Kaiser-TCS MSA (Sealed), #2 Exhibit B - 09-14-15 Letter from M. Byroade, #3 Exhibit C - 09-2015 Emails between Epic and TCS, #4 Exhibit D - 10-2015 Emails between Epic and TCS, #5 Exhibit E - 05-28-14 Email from P. Guionnet) (Neider, Barbara) Modified on 10/16/2015: Corrected docket event and linked to the redacted document. (lak)
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Filing 119
Declaration of Melissa Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Opposition re: #107 Motion to Compel, (Sealed Document) (Attachments: #1 Exhibit A - Excerpts of Kaiser-TCS MSA, #2 Exhibit B - 09-14-15 Letter from M. Byroade, #3 Exhibit C - 09-2015 Emails between Epic and TCS, #4 Exhibit D - 10-2015 Emails between Epic and TCS, #5 Exhibit E - 05-28-14 Email from P Guionnet) (Neider, Barbara) Modified on 10/16/2015. (lak)
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Filing 118
Redaction to #117 Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara) Modified on 10/16/2015: Corrected docketing event and linked to the redacted document. (lak)
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Filing 117
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #107 Motion to Compel filed by Epic Systems Corporation. (Sealed Document) (Neider, Barbara)
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Set Hearing as to #107 Motion to Compel Production of Document Over Which Defendants Have Improperly Asserted Privilege and #112 Motion to Compel Rule 30(b)(6) Deposition Testimony from Defendants. Telephone Motion Hearing set for 10/20/2015 at 02:30 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (kwf)
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Filing 116
Redaction to #114 Declaration of Rick Richmond, (Attachments: #1 Exhibit 1-Rule 30(b)(6) Deposition Notice, #2 Exhibit 2-Rule 30(b)(6) Deposition Notice, #3 Exhibit 3-Rule 30(b)(6) Deposition Notice, #4 Exhibit 4-Notice of Deposition of Syama Sundar, #5 Exhibit 5-Excerpts of the Aug. 28, 2015 Deposition of Syama Sundar (See #92 for rough draft of this deposition.), #6 Exhibit 6-Excerpts of the Sept. 24, 2015 Deposition of Syama Sundar, #7 Exhibit 7-June 5, 2015 Letter to TCS's Counsel, #8 Exhibit 8-June 26, 2015 Letter to Epic's Counel, #9 Exhibit 9-Oct. 6, 2015 Letter to TCS's Counsel, #10 Exhibit 10-Oct. 8, 2015 Emails between TCS and Epic Counsel, #11 Exhibit 11-Aug. 25, 2015 Email to TCS's Counsel) (Richmond, Rick) Modified on 10/13/2015: Corrected docketing event. (lak)
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Filing 115
Redaction to #113 Brief in Support by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 10/13/2015: Corrected docketing event. (lak)
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Filing 114
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #112 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit 1-Rule 30(b)(6) Deposition Notice, #2 Exhibit 2-Rule 30(b)(6) Deposition Notice, #3 Exhibit 3-Rule 30(b)(6) Deposition Notice, #4 Exhibit 4-Notice of Deposition of Syama Sundar, #5 Exhibit 5-Excerpts of the Aug. 28, 2015 Deposition of Syama Sundar (See #92 for rough draft of this deposition.), #6 Exhibit 6-Excerpts of the Sept. 24, 2015 Deposition of Syama Sundar, #7 Exhibit 7-June 5, 2015 Letter to TCS's Counsel, #8 Exhibit 8-June 26, 2015 Letter to Epic's Counel, #9 Exhibit 9-Oct. 6, 2015 Letter to TCS's Counsel, #10 Exhibit 10-Oct. 8, 2015 Emails between TCS and Epic Counsel, #11 Exhibit 11-Aug. 25, 2015 Email to TCS's Counsel) (Richmond, Rick)
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Filing 113
Brief in Support of #112 Motion to Compel Rule 30(b)(6) Deposition Testimony from Defendants by Plaintiff Epic Systems Corporation (Sealed Document) (Richmond, Rick)
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Filing 112
Motion to Compel Rule 30(b)(6) Deposition Testimony from Defendants by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 10/16/2015. (Richmond, Rick)
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Filing 111
Redaction to #109 Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #107 Motion to Compel. (Attachments: #1 Exhibit 1-Sept. 14, 2015 Letter from TCS Counsel, #2 Exhibit 2-Sept. 14-15 Email between Epic & TCS Counsel, #3 Exhibit 3-Excerpt from KP000565 through KP000638, #4 Exhibit 4-KP015312 through KP015316, #5 Exhibit 5-Sept. 30, 2015 Letter to TCS Counsel, #6 Exhibit 6-Excerpt of the transcript of the Deposition of David G. Jones, #7 Exhibit 7-TCS00007944, #8 Exhibit 8-TCS00007936 through TCS00007937, #9 Exhibit 9-KP000058 through KP000090) (Richmond, Rick) Modified on 10/9/2015. (kwf)
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Filing 110
Redaction to #108 Brief in Support of Motion to Compel Production of Document Over Which Defendants Have Improperly Asserted Privilege by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 10/9/2015. (kwf)
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Filing 109
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation re: #107 Motion to Compel (Sealed Document) (Attachments: #1 Exhibit 1-Sept. 14, 2015 Letter from TCS Counsel, #2 Exhibit 2-Sept. 14-15 Email between Epic & TCS Counsel, #3 Exhibit 3-Excerpt from KP000565 through KP000638, #4 Exhibit 4-KP015312 through KP015316, #5 Exhibit 5-Sept. 30, 2015 Letter to TCS Counsel, #6 Exhibit 6-Excerpt of the transcript of the Deposition of David G. Jones, #7 Exhibit 7-TCS00007944, #8 Exhibit 8-TCS00007936 through TCS00007937, #9 Exhibit 9-KP000058 through KP000090) (Richmond, Rick)
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Filing 108
Brief in Support of #107 Motion to Compel Production of Document Over Which Defendants Have Improperly Asserted Privilege by Plaintiff Epic Systems Corporation (Sealed Document) (Richmond, Rick)
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Filing 107
Motion to Compel Production of Document Over Which Defendants Have Improperly Asserted Privilege by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 10/15/2015. (Richmond, Rick)
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Filing 106
Transcript of Telephone Motion Hearing, held 9/9/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Filing 105
Notice of Appearance filed by Kelly Morrison for Plaintiff Epic Systems Corporation. (Morrison, Kelly) Modified on 9/11/2015. (lak)
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Filing 104
ORDER denying without prejudice #79 Motion for Protective Order Appointing a Special Master for the Continued Deposition of Philippe Guionnet. Signed by Magistrate Judge Stephen L. Crocker on 9/9/2015. (arw)
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Filing 103
Transcript of Telephonic Motion Hearing, held 9/4/2015 before Magistrate Judge Peter Oppeneer. Court Reporter: CS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 9/9/2015 [:50] (Court Reporter CS) (cak)
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Filing 102
Supplemental Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation in Opposition re: #79 Motion for Protective Order (Attachments: #1 Exhibit 1 - 9.4-9.5.2015 Email chain re Guionnet Deposition, #2 Exhibit 2 - 9.5.2015 Email from Guionnet re TCS backup tapes, #3 Exhibit 3 - 9.7.2015 Email from Guionnet re Iyappan, #4 Exhibit 4 - 9.8.2015 Email from Guionnet re Syama's Laptop) (Richmond, Rick)
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Minute Entry for proceedings held before Magistrate Judge Peter A. Oppeneer: Telephone Motion Hearing held on 9/4/2015 re #93 Emergency Motion to Compel Production of Documents in Advance of Upcoming Depositions filed by Epic Systems Corporation [1:10] (jaf)
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Filing 101
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Opposition re: #93 Motion to Compel, (Attachments: #1 Exhibit A - January 14, 2015 TCS letter to Epic, #2 Exhibit B - Email Chain, #3 Exhibit C - April 22, 2015 letter from Epic to TCS, #4 Exhibit D - May 8, 2015 letter from TCS to Epic, #5 Exhibit E - May 15, 2015 Epic letter to TCS, #6 Exhibit F - April 23, 2015 Epic letter to TCS, #7 Exhibit G - June 5, 2015 Epic letter to TCS, #8 Exhibit H - August 24, 2015 Epic letter to TCS) (Byroade, Melissa) Modified on 9/8/2015. (lak)
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Filing 100
** TEXT ONLY ORDER **During a telephone hearing on plaintiff's emergency motion to compel production of documents #93 the court ruled as follows: By the end of today, the parties will agree on terms for searching electronic records of the four witnesses with impending depositions, to include e-mails as well as other documents. Plaintiff will advise defendant of the time periods to be given search priority. Priority in searching and production will take into consideration the timing of the deposition. Defendant will use its best efforts to produce as many responsive documents as possible prior to the depositions. To the extent that documents responsive to the discovery requests cannot be produced until after the depositions to which they relate, the court will consider whether supplemental remedies are appropriate. Signed by Magistrate Judge Peter Oppeneer on 9/4/2015. (arw)
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Filing 99
Disregard. See #101 . Modified on 9/7/2015. (lak)
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Filing 98
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #93 Motion to Compel filed by Epic Systems Corporation. (Byroade, Melissa)
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Set Deadlines and Hearings re: #93 Emergency Motion to Compel by Plaintiff Epic Systems Corporation. Brief in Opposition due 9/3/2015 by noon. Telephone Motion Hearing set for 9/4/2015 at 10:30 AM before Magistrate Judge Peter Oppeneer. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 261-5795. (arw)
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Filing 97
Exhibit re: #93 Motion to Compel filed by Epic Systems Corporation. Exhibit 7-TCS00007625-7654 (Sealed Document) (Attachments: #1 Exhibit 9-TCS00007625-7654, #2 Exhibit 11-KP000863, #3 Exhibit 14-TCS00000146-156, #4 Exhibit 18-TCS00008335, #5 Exhibit 19-TCS00008337-8340) (Richmond, Rick) Modified on 9/1/2015. (lak)
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Filing 96
Declaration of Kate T. Spelman filed by Plaintiff Epic Systems Corporation re: #93 Motion to Compel, (Attachments: #1 Exhibit 1-August 19-21, 2015 Email Chain, #2 Exhibit 2-August 20, 2015 Email from K. Spelman to M. Byroade, #3 Exhibit 3-August 26-28, 2015 Email Chain, #4 Exhibit 4-March 29, 2015 Email from P. Guionnet, #5 Exhibit 5-May 15, 2015 Letter from K. Spelman to M. Byroade, #6 Exhibit 6-May 27, 2015 TCS America and India Responses to Plaintiff Epic's Second Set of RFPs, #7 Exhibit 7-TCS00007625-7654 (Filed Under Seal), #8 Exhibit 8-January 15-March 12, 2015 Email Chain, #9 Exhibit 9-KP000863 (Filed Under Seal), #10 Exhibit 10-April 22, 2015 Letter from K. Spelman to M. Byroade, #11 Exhibit 11-TCS00000146-156 (Filed Under Seal), #12 Exhibit 12-April 10, 2015 30(b)(6) Depo Notice of TCS, #13 Exhibit 13-May 8, 2015 Letter from M. Byroade to K. Spelman and N. Saros, #14 Exhibit 14-TCS00000001-2 (Filed Under Seal), #15 Exhibit 15-August 24, 2015 Email from K. Spelman to M. Byroade, #16 Exhibit 16-July 9, 2015 Letter from K. Spelman to M. Byroade, #17 Exhibit 17-July 25, 2015 Email from K. Spelman to M. Byroade, #18 Exhibit 18-TCS00008335 (Filed Under Seal), #19 Exhibit 19-TCS00008337-8340 (Filed Under Seal) (Richmond, Rick) Modified on 9/1/2015. (lak)
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Filing 95
Redaction to #94 Brief in Support of Motion to Compel Production of Documents in Advance of Upcoming Depositions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 94
Brief in Support of #93 Motion to Compel Production of Documents in Advance of Upcoming Depositions by Plaintiff Epic Systems Corporation. (Sealed Document) (Richmond, Rick)
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Filing 93
Emergency Motion to Compel Production of Documents in Advance of Upcoming Depositions by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 9/8/2015. (Richmond, Rick)
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Filing 92
Deposition of Syama Sundar taken on August 28, 2015 (Rough Transcript). (Sealed Document) (Richmond, Rick) Modified on 8/31/2015. (lak)
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Filing 91
Deposition of Ramesh Gajaram taken on August 13, 2015 (Rough Transcript). (Sealed Document) (Richmond, Rick) Modified on 8/31/2015. (lak)
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Filing 90
Declaration of Rick Richmond filed by Plaintiff Epic Systems Corporation in Support of Brief in Opposition re: #79 Motion for Protective Order (Attachments: #1 Exhibit 1-TCS Subpoena Duces Tecum to Phillipe Guionnet, #2 Exhibit 2-Email from Melissa Byroade re: Subpoena to Guionnet, #3 Exhibit 3-Epic's Subpoena Duces Tecum to Philippe Guionnet, #4 Exhibit 4-Epic's Subpoena for Deposition of Philippe Guionnet, #5 Exhibit 5-Letter to TCS re Philippe Guionnet Production, #6 Exhibit 6-TCS Letter Requesting Postponement of Guionnet Deposition, #7 Exhibit 7-July 31, 2015 Telephonic Hearing Transcript (Also see #76 .), #8 Exhibit 8-August 12-15, 2015 Emails re Close of the P. Guionnet Deposition, #9 Exhibit 9-Guionnet's Response to Emails re: Close of the P. Guionnet Deposition, #10 Exhibit 10-March 5, 2015 Hearing Transcript re: Motion to Compel) (Richmond, Rick) Modified on 8/31/2015. (lak)
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Filing 89
Redaction to #88 Brief in Opposition by Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 8/31/2015: Corrected docketing event. (lak)
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Filing 88
Brief in Opposition by Plaintiff Epic Systems Corporation re: #79 Motion for Protective Order filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Richmond, Rick)
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Filing 87
Deposition of Philippe Guionnet taken on August 5, 2015. (Sealed Document) (Richmond, Rick) Modified on 8/31/2015: To be refiled in condensed format. (lak)
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Filing 86
Redaction to #85 Declaration, by Defendants Tata America International Corporation, Tata Consultancy Services Limited, (Attachments: #1 Exhibit A--True and correct copy of Mr. Guionnet's August 26, 2015 email and attached document) (Neider, Barbara) Modified on 8/27/2015. (lak)
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Filing 85
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #79 Motion for Protective Order, (Sealed Document) (Attachments: #1 Exhibit A--True and correct copy of Mr. Guionnet's August 26, 2015 email and attached document) (Neider, Barbara) Modified on 8/27/2015. (lak)
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Filing 84
Deposition of Philippe Guionnet taken on August 12, 2015 (Final Draft). (Sealed Document) (Attachments: #1 Cover Letter re: Guionnet deposition) (Neider, Barbara) Modified on 8/27/2015. (lak)
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Set Deadlines and Hearings re: #79 Motion for Protective Order Appointing Special Master for the Continued Deposition of Philippe Guionnet. Response due 8/28/2015. Telephone Motion Hearing set for 9/9/2015 at 11:00 AM before Magistrate Judge Stephen L. Crocker. Counsel for Defendant responsible for setting up the call to chambers at (608) 264-5153. (arw/slc)
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Filing 83
Redaction to #82 Declaration, by Defendants Tata America International Corporation, Tata Consultancy Services Limited (Attachments: #1 Exhibit A--Email chain dated August 12, 2015 to August 15,2015, #2 Exhibit B--Guionnet Letter dated August 18, 2015, #3 Exhibit C--Richmond email dated August 19, 2015, #4 Exhibit D--Guionnet email dated August 21, 2015) (Neider, Barbara)
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Filing 82
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #79 Motion for Protective Order (Sealed Document) (Attachments: #1 Exhibit A--Email chain dated August 12, 2015 to August 15,2015, #2 Exhibit B--Guionnet Letter dated August 18, 2015, #3 Exhibit C--Richmond email dated August 19, 2015, #4 Exhibit D--Guionnet email dated August 21, 2015) (Neider, Barbara)
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Filing 81
Redaction to #80 Brief in Support of Motion for Protective Order Appointing A Special Master for the Continued Deposition of Philippe Guionnet by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 80
Brief in Support of #79 Motion for Protective Order Appointing a Special Master for the Continued Deposition of Philippe Guionnet by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Sealed Document) (Neider, Barbara)
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Filing 79
Motion for Protective Order Appointing a Special Master for the Continued Deposition of Philippe Guionnet by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Neider, Barbara)
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Filing 78
Deposition of Philippe Guionnet taken on August 12, 2015 (Rough Draft). (Sealed Document) (Neider, Barbara) Modified on 8/21/2015. (lak)
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Filing 77
** TEXT ONLY ORDER **ORDER granting #73 Joint Motion for Extension of Time to File Dispositive Motions. The new deadline to file dispositive motions is November 9, 2015, with responses due by December 1, 2015 and replies due by December 11, 2015. With a firm trial date of April 4, 2016, the schedule does not allow for any more extensions of these deadlines, so none will be granted. Signed by Magistrate Judge Stephen L. Crocker on 8/6/2015. (arw)
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Reset Deadlines and Hearings: Dispositive Motions due 11/9/2015. (arw)
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Filing 76
Transcript of Audio Recording Telephonic Hearing, held 7/31/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (voc)
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Filing 75
Declaration of Kate T. Spelman filed by Plaintiff Epic Systems Corporation re: #73 Motion for Extension of Time. (Richmond, Rick)
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Filing 74
Brief in Support of #73 Motin for Extension of Time to File Dispositive Motions by Plaintiff Epic Systems Corporation. (Richmond, Rick)
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Filing 73
Joint Motion for Extension of Time to File Dispositive Motions by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. (Richmond, Rick)
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Filing 72
** TEXT ONLY ORDER **On July 31, 2015, the court held a telephonic hearing on defendants' Emergency Motion for a protective order (dkt. #69 ). Both sides were represented by counsel. In discussion with counsel, the court granted the motion in very small part and denied it in the main. The deposition will go forward next week, but it will not start until Tuesday, August 4, 2015, and the defendant is entitled to some of the time to ask the witness substantive questions. The parties are to be further guided by the court's directions provided at the hearing. Signed by Magistrate Judge Stephen L. Crocker on 7/31/15. (jat)
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Filing 71
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited In Support re: #69 Motion for Protective Order, (Attachments: #1 Exhibit A - 07/26/15 Letter - TCS to Epic, #2 Exhibit B - 07/27/15 Letter - Epic to TCS, #3 Exhibit C - 12/08/14 Hearing Transcript, #4 Exhibit D - 04/17/15 Subpoena - Epic to Guionnet, #5 Exhibit E - June, 2015 Emails between TCS and Epic, #6 Exhibit F - 07/24/15 Letter - TCS to Epic, #7 Exhibit G - 07/30/15 Email - Epic to TCS) (Byroade, Melissa)
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Filing 70
Brief in Support of #69 Motion for Protective Order, by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Byroade, Melissa)
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Filing 69
Emergency Motion for Protective Order Staying the Deposition of Philippe Guionnet Scheduled for August 3-5, 2015 by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Byroade, Melissa) Modified on 8/3/2015. (lak)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 7/31/2015 [:45] (cak)
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Filing 68
Transcript of Telephonic Motion Hearing, held 6/29/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 67
** TEXT ONLY ORDER **On June 29, 2015, the court held a telephonic hearing on plaintiff's motion to compel certain specified types of discovery #60 . Over the course of the discussion with counsel for both sides, the court granted the motion in part and denied it in part in the manner and for the reasons stated. The court also provided directions to the parties about what needs to happen next with these discovery issues. Each side will bear its own costs on this motion. Signed by Magistrate Judge Stephen L. Crocker on 6/29/2015. (arw)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 6/29/2015 [:55] (Court Reporter LS) (cak)
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Set/Reset Deadlines as to #60 Motion to Compel Further Responses to Interrogatories and Requests for Production, and the Production of Defendants' Witnesses in the United States. Telephone Motion Hearing set for 6/26/2015 at 10:30 AM rescheduled to 6/29/2015 at 10:30 AM to accommodate the court's calendar. Counsel for Plaintiff remains responsible for setting up the call to chambers at (608) 264-5153. (cak)
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Filing 66
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Opposition re: #60 Motion to Compel, (Attachments: #1 Exhibit A - Epic Expedited Discovery Requests to TCS, #2 Exhibit B - Hearing Transcript 01-22-15, #3 Exhibit C - TCS Responses and Objections to First Set of Document Requests, #4 Exhibit D - Hearing Transcript- 03-05-15, #5 Exhibit E - Notice of Subpoenas to Guionnet, #6 Exhibit F - Letter TCS to Epic 04-15-15, #7 Exhibit G - Email Meet and Confer- 04-2015, #8 Exhibit H - Hearing Transcript 12-08-14, #9 Exhibit I - Email Potential Depositions - 02-2015, #10 Exhibit J - Letter Epic to TCS 04-23-15, #11 Exhibit K - Letter Epic to TCS 05-15-15) (Byroade, Melissa)
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Filing 65
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #60 Motion to Compel, filed by Epic Systems Corporation. (Byroade, Melissa)
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Filing 64
Declaration of Kate T. Spelman filed by Plaintiff Epic Systems Corporation re: #60 Motion to Compel, (Attachments: #1 Exhibit 1-Epic's First Set of Interrogatories to TCS India, #2 Exhibit 2-Epic's First Set of Interrogatories to Tata America, #3 Exhibit 3-Epic's Second Set of RFPs to TCS India, #4 Exhibit 4-Epic's Second Set of RFPs to Tata America, #5 Exhibit 5-30(b)(6) Depo Notice of Tata Consultancy Services Ltd and Tata America Int'l Corp (May 25, 2015), #6 Exhibit 6-30(b)(6) Depo Notice of Tata Consultancy Services Ltd and Tata America Int'l Corp (May 26, 2015), #7 Exhibit 7-30(b)(6) Depo Notice of Tata Consultancy Services Ltd and Tata America Int'l Corp (May 27, 2015), #8 Exhibit 10-TCS America and India Responses to Plaintiff Epic's Second Set of RFPs, #9 Exhibit 11-TCS Resp. and Obj. to 30(b)(6) Depo Notice of TCS and Tata America Int'l Corp (May 25, 2015), #10 Exhibit 12-TCS Resp. and Obj. to 30(b)(6) Depo Notice of TCS and Tata America Int'l Corp (May 26, 2015), #11 Exhibit 13-TCS Resp. and Obj. to 30(b)(6) Depo Notice of TCS and Tata America Int'l Corp (May 27, 2015), #12 Exhibit 14-Correspondence re Defendants' Responses to Epic's discovery requests and Rule 30(b)(6) notices, #13 Exhibit 15-Correspondence re June 4 Meet and Confer, #14 Exhibit 16-Epic Letter to TCS (06-05-15), #15 Exhibit 17-Epic Letter to TCS (04-23-15), #16 Exhibit 18-Tips For Taking Depositions In India For US Litigation - Law360, #17 Exhibit 19-Epic Letter to TCS (05-15-15), #18 Exhibit 20-Hearing Transcript (01-22-15)) (Richmond, Rick)
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Set Deadlines and Hearings re: #60 Motion to Compel Further Responses to Interrogatories and Requests for Production, and the Production of Defendants' Witnesses in the United States. Telephone Motion Hearing set for 6/26/2015 at 10:30 AM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (arw/slc)
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Filing 63
Exhibit to #61 Declaration of Kate T. Spelman filed by Epic Systems Corporation Exhibit 9-TCS America's Response to Plaintiff Epic's First Set of Interrogatories (Sealed Document) (Richmond, Rick) Modified on 6/18/2015. (arw)
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Filing 62
Exhibit to #61 Declaration of Kate T. Spelman filed by Epic Systems Corporation Exhibit 8-TCS India's Response to Plaintiff Epic's First Set of Interrogatories (Sealed Document) (Richmond, Rick) Modified on 6/18/2015. (arw)
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Filing 61
Disregard; corrected and refiled as entry #64 Declaration of Kate Spelman. Modified on 6/22/2015. (arw)
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Filing 60
Motion to Compel Further Responses to Interrogatories and Requests for Production, and the Production of Defendants' Witnesses in the United States by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 6/24/2015. (Richmond, Rick)
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Filing 59
ORDER granting in part and denying in part #52 Motion for Extension of Time to respond to plaintiff's requests for admissions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Signed by Magistrate Judge Stephen L. Crocker on 6/8/2015. (arw)
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Filing 58
Transcript of Telephone Motion Hearing, held 5/22/2015 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Filing 57
Notice of Appearance filed by Martha Jahn Snyder for Plaintiff Epic Systems Corporation. (Snyder, Martha)
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Filing 56
Declaration of Kate T. Spelman re: #52 Motion for Extension of Time, (Attachments: #1 Exhibit 1-Epic RFAs to TCS India, #2 Exhibit 2-Epic RFAs to TCS America, #3 Exhibit 3-April 3, 2015 Email from K. Spelman, #4 Exhibit 4-May 5, 2015 Email from M. Byroade, #5 Exhibit 5-May 5, 2015 Email from K. Spelman (1 of 2), #6 Exhibit 6-May 5, 2015 Email from K. Spelman (2 of 2), #7 Exhibit 7-May 11, 2015 Email from M. Byroade, #8 Exhibit 8-May 11, 2015 Email from K. Spelman, #9 Exhibit 9-May 15, 2015 Email from K. Spelman, #10 Exhibit 10-May 18, 2015 Email from M. Byroade) (Richmond, Rick) Modified on 5/21/2015. (lak)
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Filing 55
Brief in Opposition by Plaintiff Epic Systems Corporation re: #52 MOTION for Extension of Time, filed by Tata Consultancy Services Limited, Tata America International Corporation. (Richmond, Rick)
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Filing 54
Notice of Appearance filed by Rick L. Richmond for Plaintiff Epic Systems Corporation. (Richmond, Rick) Modified on 5/21/2015. (lak)
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Set Deadlines and Hearings re: #52 Motion for Extension of Time to respond to plaintiff's requests for admissions. Telephone Motion Hearing set for 5/22/2015 at 10:00 AM before Magistrate Judge Stephen L. Crocker. Counsel for Defendants responsible for setting up the call to chambers at (608) 264-5153. (arw/slc)
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Filing 53
Declaration of Melissa E. Byroade filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #52 MOTION for Extension of Time, (Attachments: #1 Exhibit A - Epic First Set of RFAs to Tata America, #2 Exhibit B - Epic First Set of RFAs to Tata Consultancy Services, #3 Exhibit C - Letter, Epic to TCS 04-23-15, #4 Exhibit D - Letter, TCS to Epic 05-08-15, #5 Exhibit E - Letter, TCS to Epic 04-15-15, #6 Exhibit F - Email re: Meet and Confer 04-2015, #7 Exhibit G - Email re: Discovery Deadlines 05-2015) (Byroade, Melissa)
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Filing 52
Motion for Extension of Time to respond to plaintiff's requests for admissions by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 5/20/2015. (Byroade, Melissa)
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Filing 51
Redaction to #50 Brief in Reply in Support of Defendants' Motion to Dismiss Plaintiff's Amended Complaint by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip) Modified on 3/27/2015. (lak)
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Filing 50
Brief in Reply by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Support of #43 Motion to Dismiss Plaintiff's Amended Complaint. (Sealed Document) (Robben, Philip) Modified on 3/27/2015: Changed event from Brief in Support to Brief in Reply. (lak)
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Filing 49
Exhibit 1 to #48 Declaration (TCS Email). (Sealed Document) (Saros, Nick) Modified on 3/12/2015. (lak)
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Filing 48
Declaration of Kate T. Spelman re: #43 Motion to Dismiss, (Attachments: #1 Exhibit 2 - Dr. Naresh Yallapragada's Webpage) (Saros, Nick) Modified on 3/12/2015 to link to the pending motion instead of the brief. (lak)
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Filing 47
Redaction to #46 Brief in Opposition by Plaintiff Epic Systems Corporation. (Saros, Nick) Modified on 3/12/2015 to correct docketing event. (lak)
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Filing 46
Brief in Opposition by Plaintiff Epic Systems Corporation re: #43 Motion to Dismiss filed by Tata Consultancy Services Limited, Tata America International Corporation. (Sealed Document) (Saros, Nick)
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Filing 45
Declaration of Philip D. Robben filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited in support re: #43 Motion to Dismiss (Attachments: #1 Exhibit A- Epic Amended Complaint, #2 Exhibit B- Epic Agreement, #3 Exhibit C- Guionnet email dated Jan 5, 2015) (Robben, Philip)
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Filing 44
Brief in Support of #43 Motion to Dismiss by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 43
MOTION TO DISMISS Plaintiff's Amended Complaint by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 3/11/2015. Brief in Reply due 3/26/2015. (Robben, Philip)
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Filing 42
Notice of Withdrawal of Motion by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #25 MOTION TO DISMISS Plaintiff's First, Second, Third, Fifth, Sixth, Seventh, Eighth, Ninth, Tenth, Eleventh, and Twelfth Causes of Action for failure to state a claim upon which relief can be granted filed by Tata Consultancy Services Limited, Tata America International Corporation. (Neider, Barbara)
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Filing 41
ORDER granting #40 Joint Motion for Entry of Stipulated Protective Order. Signed by Magistrate Judge Stephen L. Crocker on 2/1/2015. (arw)
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Filing 40
Joint Motion for Entry of Stipulated Protective Order by Plaintiff Epic Systems Corporation. (Attachments: #1 Stipulated Protective Order) (Saros, Nick) Modified on 2/2/2015. (lak)
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Filing 39
Transcript of Telephonic Motion Hearing, held January 22, 2015 before Judge William M. Conley. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (kwf)
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Filing 38
AMENDED COMPLAINT against Tata America International Corporation, Tata Consultancy Services Limited, filed by Epic Systems Corporation. (Saros, Nick)
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Filing 37
** TEXT ONLY ORDER ** On January 22, 2015, the court held a telephonic hearing on plaintiff's motion to compel defendant to comply with the court's previous orders regarding discovery (dkt. #31 ). After discussing with both sides the motion and the course of discovery to date, the court gave directions to the parties and designated some of these directions as court orders. Where we landed essentially granted the motion in part and denied it in part in the manner and for the reasons stated during the hearing. The parties however, should take to heart two of the court's parting admonitions: first, it expects them to work together efficiently, quickly and cordially to keep discovery moving forward in this case; and second, if this does not happen and a party or attorney is at fault, then this court will sanction the offending party or attorney under Rule 37(b). Each side will bear its own costs on this motion. Signed by Magistrate Judge Stephen L. Crocker on 1/22/2015. (voc)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 1/22/2015 [:45] (Court Reporter LS) (cak)
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Filing 36
Declaration of Philip D. Robben filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited in Opposition re: #31 Motion to Compel (Attachments: #1 Exhibit A - Transcript of Hearing Held 12/8/2014, #2 Exhibit B - Letter Dated 1/14/2015, #3 Exhibit C - Subpoena and Certificate of Service, #4 Exhibit D - E-mail Dated 1/5/2015, #5 Exhibit E - E-mail, #6 Exhibit F - E-mail, #7 Exhibit G - E-mail Regarding Scheduling Rule 26(f) Conference, #8 Exhibit H - E-mail Dated 12/13/2014, #9 Exhibit I - Defendants' First Set of Document Requests, #10 Exhibit J - Defendants' First Set of Interrogatories) (Robben, Philip) Modified on 1/22/2015 to add exhibit descriptions. (lak)
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Filing 35
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #31 Motion to Compel filed by Epic Systems Corporation. (Robben, Philip)
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Filing 34
Pretrial Conference Order: Amendments to Pleadings due 2/27/2015. Dispositive Motions due 10/9/2015. Settlement Letters due 1/29/2016. Motions in Limine due 2/26/2016. Response to Motion due 3/11/2016. Final Pretrial Conference set for 3/22/2016 at 4:00 PM. Jury Selection and Trial set for 4/4/2016 at 9:00 AM. Signed by Magistrate Judge Stephen L. Crocker on 1/14/2015. (arw)
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Filing 33
Declaration of Nick G. Saros filed by Plaintiff Epic Systems Corporation re: #31 Motion to Compel (Attachments: #1 Exhibit A - 12/8/14 Hearing Transcript (Also see #22 .), #2 Exhibit B - 1/6/15 Email from P. Guionnet (12:18 PM), #3 Exhibit C - 1/6/15 Email from P. Guionnet (5:05 PM), #4 Exhibit D - 01/13/15 Email communications between Counsel, #5 Exhibit E - 1/14/15 Letter from P. Robben) (Saros, Nick) Modified on 1/15/2015. (lak)
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Filing 32
Brief in Support of #31 Motion to Compel Compliance with Court Order by Plaintiff Epic Systems Corporation. (Saros, Nick)
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Filing 31
Motion to Compel Compliance with Court Order by Plaintiff Epic Systems Corporation. Motions referred to Magistrate Judge Stephen L. Crocker. Response due 1/21/2015. (Saros, Nick)
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Set Deadlines and Hearings re: #31 Motion to Compel by Plaintiff Epic Systems Corporation. Telephone Motion Hearing set for 1/22/2015 at 3:00 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (arw/slc)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Preliminary Pretrial Conference held on 1/9/2015 [:10] (cak)
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Filing 30
Corporate Disclosure Statement by Defendant Tata Consultancy Services Limited. (Robben, Philip)
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Filing 29
Corporate Disclosure Statement by Defendant Tata America International Corporation. (Robben, Philip)
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Filing 28
Joint Report of Rule 26(f) Planning Meeting. (Saros, Nick)
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Case randomly reassigned to District Judge William M. Conley and Magistrate Judge Stephen L. Crocker. (cak)
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Filing 27
Brief in Support of #25 Motion to Dismiss, by Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 26
Declaration of Philip D. Robben filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #25 Motion to Dismiss, (Attachments: #1 Exhibit A - Complaint, #2 Exhibit B - Standard Consulting Agreement) (Robben, Philip) Modified on 1/6/2015 to add exhibit descriptions. (lak)
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Filing 25
MOTION TO DISMISS Plaintiff's First, Second, Third, Fifth, Sixth, Seventh, Eighth, Ninth, Tenth, Eleventh, and Twelfth Causes of Action for failure to state a claim upon which relief can be granted by Defendants Tata America International Corporation, Tata Consultancy Services Limited. Brief in Opposition due 1/26/2015. Brief in Reply due 2/5/2015. (Robben, Philip)
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Filing 24
Notice of Appearance filed by Philip David Robben for Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Robben, Philip)
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Filing 23
Notice of Appearance filed by Melissa Errine Byroade for Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Byroade, Melissa)
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Filing 22
Transcript of Telephone Motion Hearing, held 12/8/14 before Magistrate Judge Stephen L. Crocker. Court Reporter: LS. Please review the court policy regarding electronic transcripts: see #Electronic Transcript Instructions and #Notice of Intent to Request Redaction. (arw)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 12/8/2014 re: #5 Motion to Expedite Discovery [:15] (arw)
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Filing 21
** TEXT ONLY ORDER **On December 8, 2014, the court held a telephonic hearing on plaintiff's motion to expedite discovery #5 . In discussion with the parties, the court granted the motion in part and denied it in part, in the manner and for the reasons stated. As part of its ruling, the court ordered that the parties hold their Rule 26(f) conference not later than December 23, 2014, earlier if possible. Although we did not discuss this at the hearing, because of this added workload on counsel, the court sua sponte extends to January 5, 2015 defendants' deadline to answer or otherwise respond to the complaint. Also, not later than January 5, 2015, the parties must advise the clerk's office whether they consent or decline to consent to magistrate judge jurisdiction over this lawsuit. Signed by Magistrate Judge Stephen L. Crocker on 12/8/2014. (arw)
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Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker: Telephone Motion Hearing held on 12/8/2014 re #5 Motion to Expedite Discovery filed by Epic Systems Corporation [:30] (Court Reporter ls.) (skv)
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Reset Answer Deadline: Tata Consultancy Services Limited, Tata America International Corporation answer due 1/5/2015. (arw)
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Set Pretrial Conference: Telephone Pretrial Conference set for 1/9/2015 at 2:00 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. #Standing Order Governing Preliminary Pretrial Conference attached. (arw) Modified on 12/9/2014. (arw)
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Set Deadlines as to #5 Motion to Expedite Discovery. Telephone Motion Hearing set for 12/8/2014 at 02:00 PM before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for setting up the call to chambers at (608) 264-5153. (rep)
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Filing 20
Declaration of David W. Long filed by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #5 Motion to Expedite, (Attachments: #1 Exhibit A - Epic's Homepage, #2 Exhibit B - Interview) (Vergeront, Meg)
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Filing 19
Brief in Opposition by Defendants Tata America International Corporation, Tata Consultancy Services Limited re: #5 Motion to Expedite filed by Epic Systems Corporation, (Attachments: #1 Exhibit - Long Declaration with Exhibits (Also see #20 ) (Long, David) Modified on 12/3/2014. (lak)
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Filing 18
** TEXT ONLY ORDER **ORDER accepting and entering #17 Joint Stipulation to Extend Time to Respond to the Complaint. Signed by Magistrate Judge Stephen L. Crocker on 11/25/2014. (arw)
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Filing 17
Joint Stipulation to Extend Time to Respond to the Complaint by Plaintiff Epic Systems Corporation, Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Vergeront, Meg) Modified on 11/26/2014. (lak)
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Filing 16
Notice of Appearance filed by David W. Long for Defendants Tata America International Corporation, Tata Consultancy Services Limited. (Long, David)
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Reset Answer Deadline: Tata America International Corporation, Tata Consultancy Services Limited answer due 12/29/2014. (arw)
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Filing 15
Summons Returned Executed. Tata America International Corporation served on 11/5/2014, answer due 11/26/2014. (Saros, Nick)
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Filing 14
Summons Returned Executed. Tata Consultancy Services Limited served on 11/5/2014, answer due 11/26/2014. (Saros, Nick) Modified on 11/13/2014. (lak)
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Filing 13
Summons Returned Executed. Tata Consultancy Services Limited served on 11/5/2014, answer due 11/26/2014. (Saros, Nick) Modified on 11/13/2014. (lak)
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Filing 12
Summons Returned Executed. Tata Consultancy Services Limited served on 11/5/2014, answer due 11/26/2014. (Saros, Nick)
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Filing 11
** TEXT ONLY ORDER **Plaintiff has filed proof that on November 6, 2014, it served its complaint, motion for expedited discovery and related documents on defendants. As of November 10, 2014, no attorneys have appeared for defendants in this lawsuit. To be fair to defendants, their response to plaintiff's motion for expedited discovery is due either seven days after counsel appears on defendants' behalf, or by the deadline for defendants to file an answer or other response, whichever occurs first. Signed by Magistrate Judge Stephen L. Crocker on 11/10/2014. (arw)
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Filing 10
Certificate of Service by Plaintiff Epic Systems Corporation as to #5 Motion to Expedite Discovery, #7 Declaration, #6 Brief in Support, #9 Declaration, #8 Declaration. (Saros, Nick)
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Filing 9
Declaration of David P. MacLeod filed by Plaintiff Epic Systems Corporation re: #5 Motion to Expedite. (Saros, Nick)
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Filing 8
Declaration of Stirling Martin filed by Plaintiff Epic Systems Corporation re: #5 Motion to Expedite. (Saros, Nick)
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Filing 7
Declaration of Nick G. Saros filed by Plaintiff Epic Systems Corporation re: #5 Motion to Expedite (Attachments: #1 Exhibit A - Epic webpage, #2 Exhibit B - Fast Facts about Kaiser Permanente, #3 Exhibit C - Tata Consultancy Services webpage, #4 Exhibit D - TCS Subsidiaries webpage, #5 Exhibit E - New York Department of State webpages, #6 Exhibit F - TCS America webpage, #7 Exhibit G - Med Mantra webpage, #8 Exhibit H - 2005 Standard Consultant Agreement, #9 Exhibit I - IPAdress.com webpage, #10 Exhibit J - Phillipe Guionnet's LinkedIn webpage, #11 Exhibit K - Proposed document requests to TCS, #12 Exhibit L - Proposed subpoena to Phillipe Guionnet) (Saros, Nick)
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Filing 6
Brief in Support of #5 Motion to Expedite Discovery by Plaintiff Epic Systems Corporation. (Saros, Nick)
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Filing 5
Motion to Expedite Discovery by Plaintiff Epic Systems Corporation. Response due 11/14/2014. (Saros, Nick)
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Filing 4
Disregard. See #5 - #10 . Modified on 11/7/2014. (lak)
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Filing 3
Summons Issued as to Tata America International Corporation, Tata Consultancy Services Limited. (Attachments: #1 Summons - Tata Consultancy Services Ltd. - California, #2 Summons - Tata America International Corp.) (arw)
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Case randomly assigned to Magistrate Judge Stephen L. Crocker. (arw)
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Standard attachments for Magistrate Judge Stephen L. Crocker required to be served on all parties with summons or waiver of service: #Corporate Disclosure Statement, #Order Regarding Assignment of Civil Cases, #Notice of Assignment to Magistrate Judge and Consent/Request for Reassignment, #Order on Dispositive Motions. (arw)
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Filing 2
Corporate Disclosure Statement by Plaintiff Epic Systems Corporation. (Tomaselli, Anthony)
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Filing 1
COMPLAINT against Tata America International Corporation, Tata Consultancy Services Limited. (Filing fee $400, receipt number 0758-1438584) filed by Epic Systems Corporation. (Attachments: #1 JS-44 Civil Cover Sheet, #2 Summons - Tata Consultancy Services Ltd. - New York, #3 Summons - Tata Consultancy Services Ltd. - California, #4 Summons - Tata America International Corp.) (Tomaselli, Anthony)
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