JOINT STIPULATION REQUESTING MODIFICATION TO SCHEDULING ORDER; [PROPOSED ORDER]

JON S. TIGAR, District Judge.

Pursuant to Civil Local Rule 6-2, the parties to this action respectfully submit the following Joint Stipulation Requesting Modification to the Court's Scheduling Order (D.E. #105), dated October 10, 2014.

1. The fact discovery cut-off, which is currently August 7, 2015, shall be extended until September 8, 2015; the expert disclosures deadline, which is presently August 7, 2015, shall be extended until September 8, 2015; the expert rebuttal deadline, which is presently August 28, 2015, shall be extended until September 29, 2015; the expert discovery deadline, which is presently October 9, 2015, shall be extended to November 9, 2015, and the deadline for dispositive motions, which is presently October 30, 2015, shall be extended to November 30, 2015.

2. The reason for the requested extension is that the parties have simultaneously requested an extension of the briefing schedule and hearing date for Emblaze's Motion to Compel Discovery (D.E. #114), the latter by three weeks to the Court's next available date after the date currently scheduled (from April 7 to April 28). The parties have been and are continuing to meet and confer to resolve the issues raised in Emblaze's motion, have resolved some of those issues, and believe that the additional time will greatly increase the likelihood that they will reach agreement on the remaining issues and avoid the need for the Court's intervention or any further briefing. The parties are requesting an extension of the close of fact discovery and the window for expert discovery by 30 days to allow additional time for document review and deposition preparation in case the resolution of discovery issues pushes out the time within which Emblaze receives requested documents. This would still leave five months between the close of expert discovery (now proposed for November 9, 2015) and the commencement of trial on April 4, 2016, and four months between the filing of dispositive motions (now proposed for November 30, 215) and the commencement of trial.

3. The previous time modifications in this case are as follows: A Case Management Conference had originally been scheduled for February 11, 2013 (D.E. #21), before being vacated and reset to February 25, 2013, and subsequently being vacated pursuant to a Reassignment Order (D.E. #30). Subsequent to the Clerk's Notice Setting Case Management Conference (D.E. #37), the parties filed a Joint Stipulation Requesting an Extension for the Case Management Conference (D.E. #38), and an extension of 14 days was granted (D.E. #39). A Joint Statement Proposing Schedules for Summary Judgment and Claim Construction Briefing had originally been scheduled for August 27, 2013. (D.E. #47). The parties filed a Joint Stipulation Requesting an Extension for Filing Statement Proposing Schedules for Summary Judgment and Claim Construction Briefing (D.E. #48), and an extension of 2 days was granted (D.E. #49). A technology tutorial had originally been scheduled for October 29, 2013 and a claims construction hearing had originally been scheduled for November 12, 2013. (D.E. #42). Pursuant to Court Order (D.E. #57), the tutorial was continued to December 16, 2013 and the claims construction hearing was continued to December 18, 2013. Pursuant to Court Order (D.E. #60), the tutorial was subsequently continued to February 4, 2014 and the claims construction hearing was continued to February 6, 2014. Pursuant to Clerk's Notice (D.E. #61), the tutorial was continued to March 3, 2014 and the claims construction hearing continued to March 5, 2014. Pursuant to Clerk's Notice (D.E. #62), the tutorial was continued to June 9, 2014 and the claims construction hearing was continued to June 11, 2014. The parties filed a joint Stipulated Request for Order Enlarging Time in Connection With Microsoft's Motion to Disqualify Cohen & Gresser LLP As Counsel for Emblaze Ltd. (D.E. #68) and an extension of 13 days was granted for Emblaze to file its Response brief and 6 days for Microsoft to file its Reply brief (D.E. #69). The parties filed a joint Stipulated Request for Order Enlarging Time to File Declaration in Support of Emblaze's Administrative Motion to File Documents Under Seal (D.E. #130) and an extension of two days was granted for Microsoft to file a declaration addressing the sealability of the confidential documents Emblaze had submitted with its Motion to Compel (D.E. #114).

PURSUANT TO STIPULATION, IT IS SO ORDERED.