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Contract analysis / 30b6-deposition-notice-helios.docx
30b6-deposition-notice-helios.docx
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I. DEPOSITION LOGISTICS
Medium
⚑ Liability cap to check against exposure
I. DEPOSITION LOGISTICS A. Date and Time The deposition noticed herein shall commence on a date and time to be agreed upon by the parties no later than the fact discovery close date of March 6, 2026, or as otherwise ordered by the Court. GenomeDx's counsel will confer with Helios's counsel in good faith to identify mutually agreeable dates within the remaining fact discovery period. In the event the parties are unabl
II. DESIGNATION OF CORPORATE REPRESENTATIVE(S)
Medium
⚑ Liability cap to check against exposure
II. DESIGNATION OF CORPORATE REPRESENTATIVE(S) Pursuant to Federal Rule of Civil Procedure 30(b)(6), Helios is required to designate one or more persons to testify on its behalf regarding each of the topics described with reasonable particularity in Exhibit A. The persons so designated need not be officers or directors of Helios but must be persons who consent to testify on Helios's behalf and who are prepared to tes
III. DOCUMENT PRODUCTION REQUEST
Medium
⚑ Liability cap to check against exposure
III. DOCUMENT PRODUCTION REQUEST Pursuant to Federal Rule of Civil Procedure 30(b)(2), GenomeDx hereby requests that Helios produce at the deposition all non-privileged documents, communications, and electronically stored information ("ESI") within Helios's possession, custody, or control that relate to each of the fourteen (14) topics set forth in Exhibit A, to the extent such documents have not already been produce
IV. DEFINITIONS AND INSTRUCTIONS
Medium
⚑ Liability cap to check against exposure
IV. DEFINITIONS AND INSTRUCTIONS A. Definitions. As used in this Notice and in Exhibit A attached hereto, the following terms shall have the meanings ascribed below: 1. "Helios" means Defendant Helios Precision Diagnostics, Inc., a Delaware corporation, including its officers, directors, employees, agents, representatives, subsidiaries, affiliates, predecessors, successors, and any person acting or purporting to act
1. The designee or designees produced by Helios must be prepared to testify regarding Hel
1. The designee or designees produced by Helios must be prepared to testify regarding Helios's knowledge, information, and belief as a corporate entity, not merely the designee's own personal knowledge. The testimony of a Rule 30(b)(6) designee binds the corporation to the same extent as an answer to an interrogatory or a request for admission.
2. Helios is obligated to prepare its designated witnesses thoroughly and in good faith b
2. Helios is obligated to prepare its designated witnesses thoroughly and in good faith by, among other things, reviewing all relevant documents and ESI (whether or not produced in discovery), consulting with current and former employees, officers, directors, and agents who possess knowledge of the noticed topics, reviewing deposition transcripts and declarations in this matter, and taking all other reasonable steps
3. The deposition will be conducted in accordance with the Federal Rules of Civil Procedu
3. The deposition will be conducted in accordance with the Federal Rules of Civil Procedure, including Rules 30, 32, and 37, and the Local Rules for the United States District Court for the Northern District of California, including Civil Local Rules 30-1 through 30-3.
4. The Stipulated Protective Order entered by the Court on December 18, 2025 (Dkt. No. 47
Medium
⚑ Confidentiality undertaking
4. The Stipulated Protective Order entered by the Court on December 18, 2025 (Dkt. No. 47) shall govern the handling, use, and dissemination of all confidential information disclosed during the deposition. Any testimony designated as "Confidential" or "Highly Confidential — Attorneys' Eyes Only" shall be handled in accordance with the procedures set forth in the Stipulated Protective Order.
5. Unless otherwise agreed by the parties or ordered by the Court, the deposition shall b
Medium
⚑ Notice / time limit to track
5. Unless otherwise agreed by the parties or ordered by the Court, the deposition shall be subject to the seven-hour time limitation prescribed by Federal Rule of Civil Procedure 30(d)(1). GenomeDx reserves the right to seek additional time if warranted by the number of topics, the number of designees, or other circumstances. EXHIBIT A TOPICS FOR EXAMINATION PURSUANT TO RULE 30(b)(6) Helios Precision Diagnostics, Inc