Filed: Jul. 21, 2014
Latest Update: Jul. 21, 2014
Summary: STIPULATION AND [PROPOSED] ORDER TO TAKE DEPOSITIONS AFTER THE CLOSE OF FACT DISCOVERY MAXINE M. CHESNEY, District Judge. IT IS HEREBY STIPULATED by and between Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Mentor Graphics Corp. ("Mentor Graphics") as follows: WHEREAS, Federal Rule of Civil Procedure 29 provides that the Parties may stipulate to extend discovery; WHEREAS, Federal Rule of Civil Procedure 29(b) provides that Court approval is required to extend discovery, even wher
Summary: STIPULATION AND [PROPOSED] ORDER TO TAKE DEPOSITIONS AFTER THE CLOSE OF FACT DISCOVERY MAXINE M. CHESNEY, District Judge. IT IS HEREBY STIPULATED by and between Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Mentor Graphics Corp. ("Mentor Graphics") as follows: WHEREAS, Federal Rule of Civil Procedure 29 provides that the Parties may stipulate to extend discovery; WHEREAS, Federal Rule of Civil Procedure 29(b) provides that Court approval is required to extend discovery, even where..
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STIPULATION AND [PROPOSED] ORDER TO TAKE DEPOSITIONS AFTER THE CLOSE OF FACT DISCOVERY
MAXINE M. CHESNEY, District Judge.
IT IS HEREBY STIPULATED by and between Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Mentor Graphics Corp. ("Mentor Graphics") as follows:
WHEREAS, Federal Rule of Civil Procedure 29 provides that the Parties may stipulate to extend discovery;
WHEREAS, Federal Rule of Civil Procedure 29(b) provides that Court approval is required to extend discovery, even where the Parties have stipulated to the extension;
WHEREAS, fact discovery in this case closes on July 18, 2014 (Dkt. No. 145);
WHEREAS, the Parties desire to take the deposition of certain identified witnesses after the close of fact discovery due to witness availability and/or attorney availability;
WHEREAS, good cause exists for allowing the Parties to take the desired depositions;
IT IS, THEREFORE, AGREED AND STIPULATED, AS FOLLOWS:
1. Parties have agreed to the below schedule to depose the listed witnesses after the close of fact discovery:
Deponent Deposition Date
Thomas Delaye July 22, 2014
Bob Erickson July 22, 2014
Meera Srinivasan July 24, 2014
Brent Gregory, Rule 30(b)(6) July 25, 20141
Topics 5, 11(b), 46, 47, and
50
Praveen Devulapalli July 31, 2014
Angela Sutton July 31, 2014
Aart de Geus August 5, 20142
The last fact deposition currently scheduled will occur on August 5, 2014.
2. The Parties have agreed that the witnesses disclosed in the Parties' Initial Disclosures for the first time on or after July 10, 2014 will be made available for deposition after the close of fact discovery, provided the request for deposition is made before the close of fact discovery.
3. The Parties have agreed that any motions to compel relating to any deposition in the above table shall be due one week (seven calendar days) following the deposition. (See L.R. 37-3.)
IT IS SO STIPULATED.
Pursuant to Civil Local Rule 5-1(i)(3), the filer of this document attests that concurrence in the filing of this document has been obtained from the other signatory above.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
