Which we believe to be at the heart of settlement negotiations.  This I believe is the depo taken during the Calif Trial.  Pls correct me if I'm mistaken.  Apparently exhibit 17 of huge import for both sides.  Opty

New Pacer--DEFENDANT NEC ELECTRONICS AMERICA, INC.’S AGREED MOTION TO EXPEDITE BRIEFING OF ITS MOTION CHALLENGING PLAINTIFFS’ ATTORNEY-CLIENT PRIVILEGE DESIGNATION OF SHAW DEPOSITION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION TECHNOLOGY PROPERTIES LIMITED,
et al.,
Plaintiff,
v.
MATSUSHITA ELECTRIC INDUSTRIAL CO., LTD, et al.,
Defendants.
DEFENDANT NEC ELECTRONICS AMERICA, INC.’S AGREED MOTION TO EXPEDITE BRIEFING OF ITS MOTION CHALLENGING PLAINTIFFS’ ATTORNEY-CLIENT PRIVILEGE DESIGNATION OF SHAW DEPOSITION EXHIBIT 17
Defendant NEC Electronics America, Inc. (“NECELAM”) respectfully requests the Court’s permission for expedited briefing and resolution of NECELAM’s opposed Motion Challenging Plaintiffs’ Attorney-Client Privilege Designation of Shaw Deposition Exhibit 17, filed concurrently herewith. Plaintiffs TPL and Patriot have agreed to file their respective opposition papers on or before Friday October 12, 2007. NECELAM has agreed to file its reply on or before Wednesday October 17, 2007. NECELAM respectfully requests expedited resolution of the issues presented in NECELAM’s Motion on the ground that the issues presented in that Motion and the use of Shaw Deposition Exhibit 17 will impact depositions that are currently being scheduled, including the deposition of nonparty Drew Hamilton which is currently scheduled for November 1, 2007. Plaintiffs TPL and Patriot have agreed to this Motion to Expedite.
WHEREFORE, NECELAM respectfully requests that the Court grant this Motion for expedited briefing and resolution of its opposed Motion Challenging Plaintiffs’ Attorney-Client Privilege Designation of Shaw Deposition Exhibit 17. A proposed Order granting this relief is being submitted with this Motion.
Dated: October 5, 2007
Respectfully submitted,
Anthony H. Son
Guy N. Harrison, State Bar No. 00000077
gnharrison@att.net
Attorney at Law
217 N. Center
Longview, TX 75601
CERTIFICATE OF SERVICE
I hereby certify that on October 5, 2007, all counsel of record who are deemed to have consented to electronic service are being served with a copy of the foregoing instrument via the Court’s CM/ECF filing system.
/s/ Anthony H. Son