All Documents and Things responsive to any Request for Production served by Plaintiffs that were, but are no longer, in Defendants’ possession, custody or control. Case 1:15-cv-07025-RBK-JS Document 187-13 Filed 02/21/17 Page 34 of 36 PageID: 8615 PLAINTIFFS AMENDED FIRST DEPOSITION NOTICE PURSUANT TO FED. R. CIV. P 30(B)(6) ATTACHMENT B 18 96. All Documents and Things produced to Defendants by any third party or non- party to This Action, by subpoena or otherwise.

The gross and net profitability of any products identified in Topic 37 on a monthly, quarterly, and annual basis from the first sale of the Accused Products to the present, including how Defendants determine those amounts. Case 1:15-cv-07025-RBK-JS Document 193-2 Filed 02/27/17 Page 23 of 30 PageID: 9060 PLAINTIFFS SECOND DEPOSITION NOTICE PURSUANT TO FED. R. CIV. P 30(B)(6) ATTACHMENT B 7 37. Manner in which each of Xactware and Verisk compute their net profits in the normal course of business, the specific cost factors associated with the Accused Products, and the manner in which each of Xactware and Verisk maintain their financial records relating to the Accused Products.

However, Ameren opposes expanding the 25-deposition limit and/or extending the discovery cut-off. Because EPA has additional Rule 30(b)(6) topics upcoming, and has noticed two additional 30(b)(6) depositions, Ameren would also appreciate the Court’s guidance on the rules to be applied to those depositions going forward. Dated: June 26, 2014 Respectfully submitted, /s/ Matthew B. Mock Case: 4:11-cv-00077-RWS Doc. #: 272 Filed: 06/26/14 Page: 13 of 15 PageID #: 6051 13 Ronald S. Safer (pro hac vice) Patricia Brown Holmes (pro hac vice) Renee Cipriano (pro hac vice) Steven J. Bonebrake (pro hac vice) Matthew B. Mock (pro hac vice) SCHIFF HARDIN LLP 233 South Wacker Drive, Suite 6600 Chicago, Illinois 60606 (312) 258-5500 Fax: (312) 258-5600 James J. Virtel ARMSTRONG TEASDALE LLP 7700 Forsyth Boulevard Suite 1800 St. Louis, Missouri 63105 (314) 621-5070 Fax: (314) 612-2298 jvirtel@armstrongteasdale.com Counsel for Defendant Ameren Missouri Case: 4:11-cv-00077-RWS Doc. #: 272 Filed: 06/26/14 Page: 14 of 15 PageID #: 6052 CERTIFICATE OF SERVICE I hereby certify that on Ju

Case3:09-cv-00901-MHP Document49 Filed12/21/09 Page9 of 10 -10- DEFENDANTS BART AND CHIEF GEE’S NOTICE OF MOTION AND MOTION TO ALLOW ADDITIONAL TIME FOR DEPOSITIONS (F.R.C.P. 30(d)(1)); MEMORANDUM OF POINTS AND AUTHORITIES J:\1752\SF0208\Pleadings\Motion Compel Depos\M-compel-depos.doc Case No. C09-00901 MHP 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IV CONCLUSION For the foregoing reasons, defendants BART and Chief Gee respectfully request that the Court allow three hours of additional time pursuant to F.R.C.P. 30(d)(1), on a day or days to be determined among all parties, for the deposition of each plaintiff/witness Carlos Reyes, Jack Bryson and Michael Greer. Dated: December 21, 2009.

IV. CONCLUSION Toshiba’s approach to discovery thus far gives Plaintiffs cause for concern should they be forced to take deposition testimony overseas. As well, the time and costs which will be incurred are prohibitive, especially given the limited availability of location and the restrictive nature of conducting depositions in Japan. For all of these reasons Plaintiffs request an Order compelling Toshiba to bring its Rule 30(b)(6) designee(s) to Chicago for deposition. Respectfully Submitted, /s/Paul C. Gibbons______________ Raymond P. Niro Joseph N. Hosteny Arthur A. Gasey Paul C. Gibbons Douglas M. Hall David J. Mahalek NIRO, SCAVONE, HALLER & NIRO 181 West Madison, Suite 4600 Chicago, Illinois 60602 Telephone: (312) 236-0733 Attorneys For New Medium Technologies LLC, AV Technologies LLC, IP Innovation LLC, and Technology Licensing Corporation

Neither Liveperson, Inc. v. 24/7 Customer, Inc., No. 14 Civ. 1559(RWS), 2015 WL 4597546 (S.D.N.Y. July 29, 2015) nor Trustees of Boston University v. Everlight Electronics Co., Ltd. (“Trustees”), No. 12–cv–11935– PBS, 2014 WL 5786492 (D. Mass. Sept. 24, 2014) disturb the requirement of Rule 30(b)(6) that a corporate representative “must testify about information known or reasonably available to the Case 3:14-cv-01849-P Document 304 Filed 12/30/15 Page 13 of 21 PageID 8747 10 organization.” See Fed. R. Civ. P. 30(b)(6). Plaintiffs, accordingly, must make available a witness to testify regarding any such non-privileged information.

If the Court does not promptly overrule Toyota’s objections and order Toyota to comply with the June 26 Order, Toyota will have successfully prevented Plaintiffs from being able to complete this crucial deposition in advance of the July 18 deadline and prevented Plaintiffs from incorporating the testimony into their expert reports. Case 8:10-ml-02151-JVS-FMO Document 2795 Filed 07/11/12 Page 10 of 11 Page ID #:94686 10 ___________________________________________________________________________________ PLAINTIFFS’ RESPONSE TO TOYOTA’S OBJECTIONS TO SPECIAL MASTERS’ JUNE 26, 2012 ORDER COMPELLING THE FED. R. CIV. P. 30(B)(6) DEPOSITION OF TOYOTA RE FIELD TECHNICAL REPORTS AND “GO AND SEE” INVESTIGATIONS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IV. CONCLUSION Under the circumstances, the Court should not wait until July 30 to address the Special Masters’ Order.

ourt will be available by telephone to address problems that may arise during such depositions. See Pro-Football, Inc. v. Harjo, 2003 WL 744629 (D.D.C. 2003) (Facciola, Magistrate J.) (ordering that second deposition take place in chambers “so that I may personally preside over the questioning”); Robertson v. Qadri, 2007 WL 1176635 (N.D. Cal. Apr. 20, 2007) (Lloyd, Magistrate J.) (ordering second deposition to take place in chambers where the court can “deal firmly with any unprofessional or inappropriate conduct”). CONCLUSION Based on the foregoing, plaintiffs respectfully request that the Court enter the accompanying proposed order prohibiting David Fox from (1) representing to any deponent that the deponent is not compelled to answer questions at deposition for any reason other than those provided in Rule 30(d)(1), and (2) raising at deposition any speaking objections that are argumentative, suggestive, or calculated to interrupt or delay the deposition in violation of Rule 30(d)(1). Should the Court deem it necessary, plaintiffs are prepared to conduct the depositions of Irwin Staten, Kimbra Staten, and Otto Hines either in chambers or under arrangements where 9 Case 1:06-cv-01561-RJL-JMF Document 118 Filed 09/27/2007 Page 11 of 14 the Court will be available by telephone to resolve any noncompliance with the Court’s instructions.

H Amended Notice of Deposition to U.S. Department of Treasury Pursuant to Fed. R. Civ. P. 30(b)(6) (Basil Kiwan) I Notice of Deposition to U.S. Department of Treasury Pursuant to Fed. R. Civ. P. 30(b)(6) (Jim Millstein) J Notice of Deposition to Board of Governors of the Federal Reserve System Pursuant to Fed. R. Civ. P. 30(b)(6) (Jon Greenlee) K Amended Notice of Deposition Pursuant to Subpoena (Michael Hsu) Case 2:08-cv-15147-LPZ-MKM Document 36 Filed 01/15/2010 Page 32 of 32

For all the reasons stated here and in the letter dated October 22, 2009, this Court should quash these deposition notices. WHEREFORE, the Defendants pray that this Court quash those Fed. R. Civ. P. 30(b)(6) depositions served on Defendants on or about October 20, 2009; grant them the costs of bringing this motion, including reasonable attorneys’ fees; and grant them such other and further relief as this Court deems proper. Case 1:07-cv-01367 Document 622 Filed 10/28/2009 Page 8 of 9 9 Respectfully submitted, CCJ INVESTMENTS, LLC BRB INVESTMENTS, LLC SI BOO, LLC CCPI, LLC CMS SERVICES, LLC AZTEK PARTNERS LLC CHONUS LLC By: ___/s/ Harold Moskowitz_______ One of their Attorneys HAROLD L. MOSKOWITZ 55 West Monroe Street Suite 1100 Chicago, Illinois 60603 (312) 977-0223 ARDC: 3128347 DONALD LEVINE LATIMER LEVAY & JURASIK, LLC 55 West Monroe Street Suite 1100 Chicago, Illinois 60603 (312) 422-8000 ARDC: 1637355 Case 1:07-cv-01367 Document 622 Filed 10/28/2009 Page 9 of 9