S ILLS C UMMIS & G ROSS A PROFESSIONAL CORPORATION

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Trent S. Dickey 

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December 8, 2011 

FILED ELECTRONICALLY

Honorable Michael A. Shipp 

U.S. Magistrate Judge 

Martin Luther King Jr. Federal Bldg. & Courthouse 

50 Walnut Street 

Newark, NJ 07102 

Re: Kenwood Appliances Luxembourg, S.A., et al. v. Home Depot U.S.A., Inc., et al. 

Civil Action No. 10-cv-06356 (SRC)(MAS) 

Dear Magistrate Judge Shipp: 

One behalf of Defendants China Singfun Electric Group Co. Ltd. (“China Singfun”) and 

Kenworld International Company, Ltd. (“Kenworld”) and the other parties, I write pursuant to 

the Court’s instruction to submit a joint letter, updating the Court on the current status of 

discovery in the above-captioned matter. In addition, this will confirm my telephone discussion 

with your Chambers yesterday, wherein I requested an adjournment of the December 15, 2011 

10:30 a.m. telephone status conference, with the consent of all parties. 

As to the telephone status conference, I will be out of state in a poor cell phone area on 

December 15th. All the parties are available for a rescheduled status call on December 20th, 21st

in the afternoon, and December 22nd before 2 PM. Home Depot’s lead counsel, Mr. Potenza, is 

on vacation the following week. 

Consistent with the Pretrial Scheduling Order, the parties served interrogatories and 

requests for the production of documents in May, 2011. The parties responded to each others 

interrogatories in June, 2011. Kenworld and China Singfun served amended answers to 

plaintiffs’ interrogatories on November 17, 2011. 

Case 2:10-cv-06356-SRC -MAS Document 38 Filed 12/07/11 Page 1 of 2 PageID: 213
SILLS CUMMIS & GROSS A P ROFESSIONAL C ORPORATION

Honorable Michael A. Shipp 

December 7, 2011 

Page 2 

 

Home Depot initially produced responsive documents to Plaintiff Kenwood Appliances 

Luxembourg, S.A., (“Kenwood”) on June 23, 2011, and supplemented its production on 

October 28, 2011 to all plaintiffs. In total, Home Depot reports it has produced 13,385 

documents, including paper documents, emails, and electronic files. Emails and their 

attachments have been counted as separate documents. On September 30, 2011, Home Depot 

provided additional information concerning document requests and interrogatory responses in a 

letter to Plaintiffs’ counsel. China Singfun and Kenworld initially produced their responsive 

documents in June, 2011 and supplemented their production on November 10, 2011 producing a 

total of 6,959 pages of documents to date. Plaintiffs’ document production was made on June 23, 

2011 and Plaintiffs have produced 936 pages of documents. Home Depot served Plaintiffs with 

additional requests for the production of documents recently, and China Singfun anticipates 

producing some additional documents as to its costs and expenses in the near future. 

To date, depositions of the defendants have been taken as follows: (1) Christian Jessel, 

Home Depot; (2) Dominic Piccininni, Home Depot; (3) Jerry Ren, China Singfun; and (4) 

Samantha Yao, China Singfun and on behalf of Kenworld. Defendants China Singfun and 

Kenworld have noticed the depositions of officers or representatives from Plaintiffs, though 

these depositions have yet to be scheduled. 

The deadline for fact discovery is currently December 15, 2011. The parties respectfully 

jointly request that the discovery deadline be extended by two months, until February 15, 2012. 

Respectfully submitted, 

TRENT S. DICKEY 

cc: John R. Altieri, Esq. (by e-mail) 

Rudolph V. Pino, Jr., Es. (by e-mail) 

Michael R. Potenza, Esq. (by e-mail) 

Case 2:10-cv-06356-SRC -MAS Document 38 Filed 12/07/11 Page 2 of 2 PageID: 214