Case 1:07-cv-OOO17—GIV|S Document 54 Filed O1/24/2008 Page 1 of3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
KEURIG, INCORPORATED,
Plaintiff,
V- Civil Action No. 07-017 (GMS)
KRAFT FOODS GLOBAL, INC.,
TASSIMO CORPORATION, and
KRAFT FOODS INC.,
Defendants.
STIPULATION AND ORDER
REGARDING EXPERT DISCOVERY
The plaintiff and defendants in this litigation anticipate that a number of experts will be
preparing reports and testifying and therefore, in order to efficiently manage the expert
discovery, the parties agree as follows, subject to the approval of the Court:
l. No drafts of expert reports need be produced.
2. Along with the expert report, or within a reasonable time thereafter, the expert
will be required to produce to the opposing side copies of all documents and information that
were relied upon in preparing the expert’s final report. Documents not relied upon by the expert
need not be produced.
3. Discovery or questioning of expert witnesses shall not extend to the production of
documents, oral examination, or any other form of inquiry concerning:
(a) drafts, notes, or other prior work product prepared in this case and
abandoned (i.e., not being relied upon by the expert), or
Diauzzcsztisui rmsozmion
Case 1:07-cv—OOO17-Gl\/IS Document 56 Filed O1/29/2008 Page 2 of 3
Case 1:O7—cv—O0O17-Gl\/IS Document 54 Filed O1/24/2008 Page 2 of 3
(b) communications to or from or in the presence of an attorney for the party
expecting to call the expert witness, unless the expert is relying upon the communication as part
ofthe basis for his or her expert testimony.
4. The deposition of each expert shall not exceed seven (7) hours, exclusive of
breaks.
5. Nothing in this Stipulation and Order shall be construed to limit the discovery or
examination of expert witnesses concerning the basis for an expert’s final opinions or the
documents or other information considered in rendering that tinal opinion.
6. Until such time as this Stipulation and Order has been signed by the Court, the
parties agree that upon execution by all parties, it will be treated as though it had been ordered by
the Court.
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Dl302.:6$24l90,l
Case 1 :07-cv—OOO17-GIVIS Document 56 Filed O1/29/2008 Page 3 of 3
Case 1:07-cv-00017-Gl\/IS Document 54 Filed 01/24/2008 Page 3 of 3
I/l/{/gt; _/s/ Richard L. Horwitz
John W. Shaw (N o. 3362) Richard L. Horwitz (No. 2246)
Karen E. Keller (No. 4489) Kenneth L. Dorsney (N o. 3726)
YOUNG CONAWAY STARGATT & POTTER ANDERSON &
TAYLOR, LLP CORROON LLP
The Brandywine Building Hercules Plaza, 6"` Floor
1000 West Street, 17*1* Floor 1313 N. Market Street
Wilmington, DE 19801 Wilmington, DE 19801
(302) 571-6600 (302) 984-6000
l
Michael N. Rader William S. Foster, Jr.
Laura Topper C. John Brown
Gerald B. Hrycyszyn BAKER BOTTS L.L.P.
WOLF, GREENFIELD & SACKS, P.C. 1299 Pennsylvania Ave., N.W.
600 Atlantic Avenue Washington, D.C. 20004-2400
Boston, MA 02210 (202) 639-7700
(617) 646-8000 davidschlit2@bal
Arrornqysfg;-· Plaintf’[{eu;·ig, Arror·1zeys_/or Tassimo Coipomrion, Krqfi
[;yCO;p0mped Foods Global, Inc. and Krcgfl Foods [nc.
I ORDER
·i‘
IT 1S SO ORDERED this day of January, 2008.
Unitedétates District Court Judggl
F I I- E D
I JAN 2 9 2008 I
u.s. DISTRICT COURT
DISTRICT OF DELAWARE
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DB02:6524I90.I 0ca
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