No Other Discovery. From the date this Settlement Agreement is fully executed, neither Defendants nor Plaintiffs or any Settlement Class Member, shall file motions against the other or initiate or participate in any discovery, motion practice, or proceeding directly adverse to the other in connection with the Action, except as specifically provided for herein. Defendants and Plaintiffs shall not be obligated to respond or supplement prior responses to formal discovery that have been previously propounded by the other in the Action. Defendants shall retain the right, by motion or otherwise, to protect, or attempt to protect, from disclosure any and all documents and information designated as Confidential and/or Attorneys’ Eyes Only under the Discovery Confidentiality Order in this Action (ECF No. 62). Plaintiffs shall not take a position regarding any such efforts.
No Other Discovery. From and after the date this agreement is fully executed, neither KEMET nor the Class shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except as specifically provided for herein. KEMET and the Class shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. From and after the date this Settlement Agreement is fully executed, neither the Settling Defendants nor the Plaintiffs or any class they purport to represent, including any Settlement Class, shall file motions against the other or initiate or participate in any discovery, motion practice, or proceeding directly adverse to the other in connection with the Action, except as specifically provided for herein. The Settling Defendants and Plaintiffs shall not be obligated to respond or supplement prior responses to formal discovery that have been previously propounded by the other in the Action. The Settling Defendants shall retain the right, by motion or otherwise, to protect, or attempt to protect, from disclosure any and all documents and information designated as Confidential under the Stipulated Protective Order in this Action (ECF No. 38).
No Other Discovery. From and after the date this Settlement Agreement is fully executed, neither Groupon nor Plaintiffs shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action.
No Other Discovery. From and after the date this agreement is fully executed, neither Taitsu nor the Class shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except that Taitsu will work in good faith to provide a corporate certification to establish that certain documents produced in this Action to be introduced at trial are business records under 803(6), recognizing that no individual will have personal knowledge of all the records and that certain limited documents may not be ordinary business records. Taitsu and the Class shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. From and after the date this agreement is fully executed, neither Shinyei nor the Class shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except that Shinyei will work in good faith to provide a corporate certification to establish that its documents produced in this Action are business records under Federal Rules of Evidence 803(6) and/or 902, recognizing that no individual will have personal knowledge of all the records. Shinyei and the Class shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. From and after the date this agreement is fully executed, neither AVX nor the Class shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except that AVX will work in good faith to provide a corporate certification to establish that certain documents produced in this Action to be introduced at trial are business records under 803(6), recognizing that no individual will have personal knowledge of all the records and that certain limited documents may not be ordinary business records. AVX and the Class shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. Upon the execution of this Settlement Agreement, neither Hitachi Chemical nor the Direct Purchaser Plaintiffs shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except as specifically provided for herein. Hitachi Chemical and the Direct Purchaser Plaintiffs shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. From and after the date this agreement is fully executed, neither NCC or UCC nor the Class shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action, except as specifically provided for herein. NCC and UCC and the Class shall not be obligated to respond or supplement prior responses to formal discovery that has been previously propounded by the other in the Action.
No Other Discovery. From and after the date this agreement is fully executed, neither Giftly nor Plaintiffs shall file motions against the other or initiate or participate in any discovery, motion, or proceeding directly adverse to the other in connection with the Action. Settlement Consideration:
