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:
1. 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 exarnination, 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
Dl302:6524l9D,§ 065927.§(l0l
Case 1:07—cv—00017-Gl\/IS Document 54 Filed 01/24/2008 Page 2 of 3
(b) communications t0 or from or in the presence of an attorney for the party
expecting to call the expert witness, unless the expert is reiying 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 Stipuiation and Order shall be construed to limit the discovery or
examination of expert witnesses concerning the basis for an expert’s finai 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 panties, it will be treated as though it had been ordered by
the Court.
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Case 1 :07-cv-00017-GIVIS Document 54 Filed 01/24/2008 Page 3 of 3
2 _/s/ Ric/lord L. Hor·wiz‘z
John W. Shaw (No. 3362) Richard L. Horwitz (No. 2246)
Karen E. Keller (No. 4489) Kenneth L. Dorsney (N 0. 3726)
YOUNG CONAWAY STARGATT & POTTER ANDERSON &
TAYLOR, LLP CORROON LLP
The Brandywine Building Hercules Plaza, 6"` Floor
1000 West Street, 17m 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 davidschlitz@bal
Arrg;-;;qygfO;· P]g[;1rgj'[{g;;;·ig, Arroi·neys_fo1· Tcnssimo Cozporcxrion, Kim'?
[;ycO;pO;·m+gd Foods Global, Inc. and Krcg]? Foods Inc.
ORDER
IT IS SO ORDERED this day of January, 2008.
United States District Court Judge
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