Filed: Apr. 30, 2015
Latest Update: Apr. 30, 2015
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DEADLINES PENDING SETTLEMENT AGREEMENT JEFFREY S. WHITE , District Judge . Pursuant to Civil L.R. 6-2, Plaintiff David R. Siskin ("Plaintiff") and Defendant Surell Accessories, Inc. ("Defendant") hereby jointly request that the Court extend all pending deadlines by 45 days to allow the parties to complete a formal settlement agreement. The parties reached settlement terms on April 29, 2015. Pursuant to Civil L.R. 6-2(a)(1), the parties state
Summary: STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DEADLINES PENDING SETTLEMENT AGREEMENT JEFFREY S. WHITE , District Judge . Pursuant to Civil L.R. 6-2, Plaintiff David R. Siskin ("Plaintiff") and Defendant Surell Accessories, Inc. ("Defendant") hereby jointly request that the Court extend all pending deadlines by 45 days to allow the parties to complete a formal settlement agreement. The parties reached settlement terms on April 29, 2015. Pursuant to Civil L.R. 6-2(a)(1), the parties state ..
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE ALL DEADLINES PENDING SETTLEMENT AGREEMENT
JEFFREY S. WHITE, District Judge.
Pursuant to Civil L.R. 6-2, Plaintiff David R. Siskin ("Plaintiff") and Defendant Surell Accessories, Inc. ("Defendant") hereby jointly request that the Court extend all pending deadlines by 45 days to allow the parties to complete a formal settlement agreement. The parties reached settlement terms on April 29, 2015.
Pursuant to Civil L.R. 6-2(a)(1), the parties state the following:
1. The parties have been discussing settlement.
2. The parties reached agreement on settlement terms and have begun drafting a formal settlement agreement, and they anticipate filing a notice of voluntary dismissal on or before May 29, 2015.
3. Accordingly, the parties jointly and respectfully request that the Court extend the pending deadlines as follows to provide sufficient time to finalize a settlement agreement and meet the terms thereof:
Presently Proposed
Event Scheduled Date Date
Last day for Plaintiff to file Answer or otherwise respond Apr. 30, 2015 June 15, 2015
to Counterclaims
Last day for Plaintiff to serve Disclosure of Asserted May 1, 2015 June 15, 2015
Claims and Infringement Contentions and
Accompanying Document Production
Last day for Defendant to serve Invalidity Contentions June 15, 2015 July 30, 2015
and Accompanying Document Production
Last day for Parties to exchange proposed claim terms June 29, 2015 Aug. 13, 2015
for construction
ADR: Court mediation to be completed July 16, 2015 Aug. 31, 2015
Parties to exchange preliminary claim construction and July 20, 2015 Sept. 3, 2015
extrinsic evidence
Deadline for either party to request leave to designate July 31, 2015 Sept. 14, 2015
more than ten terms for claim construction
Last day for Parties to file and serve joint claim Aug. 14, 2015 Sept. 28, 2015
construction and prehearing statement
Claim Construction discovery cutoff Sept. 14, 2015 Oct. 29, 2015
Last day for Plaintiff to file opening claim construction Oct. 13, 2015 Nov. 27, 2015
brief
Last day for Defendant to file responsive claim Oct. 27, 2015 Dec. 11, 2015
construction brief
Last day for Plaintiff to file reply claim construction Nov. 3, 2015 Dec. 18, 2015
brief; last day for parties to file an amended, final joint
claim construction statement
4. Pursuant to Civil L.R. 6-2(a)(2), the parties previous requested three extensions of time for Defendant to respond to and answer the Complaint. (Dkt. Nos. 12, 13, 18).
5. Pursuant to Civil L.R. 6-2(a)(3), the requested time modification would delay the current case management schedule by 45 calendar days. The tutorial set for December 3, 2015 and claim construction hearing set for December 10, 2015 are VACATED and shall be reset by further order, if necessary.
PROPOSED ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
