NATHANAEL M. COUSINS, Magistrate Judge.
Plaintiff Tessera, Inc. ("Tessera") and Defendant Toshiba Corporation ("Toshiba"), by and through their undersigned counsel of record, hereby respectfully submit this Joint Stipulation and [Proposed] Order Regarding Meet and Confer and Briefing Deadlines.
On April 6-7 and April 7-8, 2016, two depositions of Toshiba 30(b)(6) designees took place and four additional depositions of Toshiba 30(b)(6) designees are scheduled to take place on April 11-12, 12-13, 13-14, and 14-15, 2016. The parties anticipate that their meet and confer regarding the 30(b)(6) topics will be significantly aided by the deposition testimony. Moreover, the parties believe it will be difficult to reach a mutually-agreeable resolution until those depositions have taken place. Accordingly, subject to the Court's approval, the parties hereby stipulate to extend all dates and deadlines in the Court's Order (Docket No. 96) dated April 7, 2016, as follows:
1. The parties will meet and confer regarding the 30(b)(6) topics addressed by Toshiba's pending motion (Docket No. 95) promptly after the depositions taking place on April 11-15, 2016.
2. If the parties are unable to resolve the issues, Tessera's opposition to Toshiba's motion for protective order (Docket No. 95) will be due April 21, 2016 and Toshiba's reply on April 28, 2016.
3. Any hearing on Toshiba's Motion for Protective Order would occur on May 4, 2016 at 1:00 p.m. or any date thereafter convenient for the Court.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.