ANTON HANDAL (Bar No. 113812)
anh@handal-law.com
PAMELA C. CHALK (Bar No. 216411)
pchalk@handal-law.com
GABRIEL HEDRICK (Bar No. 220649)
ghedrick@handal-law.com
H
ANDAL & A
SSOCIATES
1200 Third Avenue, Suite 1321
San Diego, California 92101
Tel: 619.544.6400
Fax: 619.696.0323
Attorneys for Plaintiff and Counter-Defendant
e.Digital Corporation
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
e.Digital Corporation,
Plaintiff,
v.
FUJIFILM Corporation; FUJIFILM
Holdings Corporation; FUJIFILM
Holdings America Corporation,
Defendants.
Case No. 3:13-cv-00112-DMS-WVG
PLAINTIFF E.DIGITAL
CORPORATION’S REQUEST FOR
JUDICIAL NOTICE; NOTICE RE:
OPPOSITION TO RENEWED EX
PARTE MOTION; AND, ATTACHED
EXHIBITS 1-2
Assigned to the
Honorable Judge Dana M. Sabraw
Ctrm: 13A (Annex)
FUJIFILM Corporation; FUJIFILM
Holdings Corporation; FUJIFILM
Holdings America Corporation,
Counterclaimants,
v.
e.Digital Corporation,
Counter-Defendant.
TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR
THE SOUTHERN DISTRICT OF CALIFORNIA:
Plaintiff e.Digital Corporation (“Plaintiff”) by and through its attorney,
hereby respectfully requests the Court to take judicial notice pursuant to Federal
Rule of Evidence 201 and/or all other applicable provisions of law of the following
facts:
1) On October 21, 2013, Defendant Apple Inc. in the case
e.Digital v.
Apple Inc.
, Case No. 3:13-cv-00785-DMS-WVG filed a motion,
“Ex
Parte Application For Order Shortening Time”
(“Apple Motion”)
(Dkt #55).
2) On October 22, 2013, Defendants FUJFILM Corporation, FUJIFILM
Holdings Corporation, and FUJIFILM Holdings America Corporation
in the case
e.Digital v. FUJFILM Corporation, et al.
, Case No. 3:13-
cv-00112-DMS-WVG filed a motion, “
Renewed Ex Parte Application
For Order Shortening Time
.” (“FUJIFILM Motion”) (Dkt #70).
3) On October 23, 2013, e.Digital Corporation filed an opposition to the
Apple Motion (Dkt #58), a copy of which is attached hereto as Exhibit
1 and Exhibit 2.
Given that the FUJIFILM Motion is identical in all material respects to the
Apple Motion and in order to conserve judicial resources as well as time when
reviewing these matters, NOTICE is further given that e.Digital Corporation
opposes the FUJIFILM Motion for the same reasons and on the same basis as
stated in its opposition to the Apple Motion which is attached hereto as Exhibits 1
and 2.
It is respectfully requested that both the Apple Motion and FUJIFILM
Motions are denied.
-
HANDAL & ASSOCIATES
Dated: October 23, 2013
HANDAL & ASSOCIATES
By: /s/Pamela C. Chalk__________________
Pamela C. Chalk
Gabriel G. Hedrick
Attorneys for Plaintiff
1200 THIRD AVE
SUITE 1321
SAN DIEGO, CA 92101
TEL: 619.544.6400
FAX: 619.696.0323
Respectfully submitted,
