EAGLE HARBOR HOLDINGS, LLC v. FORD MOTOR COMPANY, 3:11-cv-05503-BHS. (2013)
Court: District Court, D. Washington
Number: infdco20131115d39
Visitors: 4
Filed: Nov. 13, 2013
Latest Update: Nov. 13, 2013
Summary: JOINT STIPULATED MOTION & ORDER TO REVISE CASE SCHEDULE BENJAMIN H. SETTLE, District Judge. Due to challenges and difficulties in scheduling certain depositions and completing party and non-party discovery in advance of the deadline for opening expert reports, as well as the parties' desire to narrow the scope of the case in advance of that deadline and upon receipt of the Court's final Markman order, the parties have conferred and reached agreement about certain revisions to the case schedu
Summary: JOINT STIPULATED MOTION & ORDER TO REVISE CASE SCHEDULE BENJAMIN H. SETTLE, District Judge. Due to challenges and difficulties in scheduling certain depositions and completing party and non-party discovery in advance of the deadline for opening expert reports, as well as the parties' desire to narrow the scope of the case in advance of that deadline and upon receipt of the Court's final Markman order, the parties have conferred and reached agreement about certain revisions to the case schedul..
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JOINT STIPULATED MOTION & ORDER TO REVISE CASE SCHEDULE
BENJAMIN H. SETTLE, District Judge.
Due to challenges and difficulties in scheduling certain depositions and completing party and non-party discovery in advance of the deadline for opening expert reports, as well as the parties' desire to narrow the scope of the case in advance of that deadline and upon receipt of the Court's final Markman order, the parties have conferred and reached agreement about certain revisions to the case schedule going forward. The requested revisions provide for modest extensions to the deadlines for opening and rebuttal expert reports, as well as the close of discovery, while maintaining deadlines that impact the Court, such as the noting dates for dispositive and Daubert motions, motions in limine, pretrial filings (pretrial order, voir dire, trial briefs, and jury instructions), and the trial date.
In addition, the parties have agreed to the entry of certain interim discovery deadlines that will afford the parties further predictability concerning scheduling of depositions and completion of document production. On this showing of good cause, the parties respectfully and jointly move for the entry of the revised deadlines set out in Exhibit 1.
It is so ordered.
Exhibit 1
Current
Event Deadline Revised Deadline
Deadline for Medius to present narrowed list
of claims (subject to changes based on claim -- 11/11/13
construction order)
Deadline for Ford to disclose list of 35 prior
art references (subject to changes based on -- 11/18/13
Medius' changes to asserted claims)
7 days after Markman order,
so long as the Markman is
Deadline for Medius to supplement received by 11/29/13
Inerrogatory response 12 (written -- If the Markman order is not
description) received by 11/29/13,
deadline is 12/6/13
Deadline for Ford to supplement response to
interrogatory 11 (design-arounds) -- 12/2/13
7 days after Markman order,
so long as the Markman is
Deadline for Medius to serve amended -- received by 11/29/13
infringement contentions If the Markman order is not
received by 11/29/13,
deadline is 12/6/13
14 days after receiving
Deadline for Ford to serve amended non-infringement -- Medius's contentions, but not
contentions later than 12/20/13
21 days after receiving
Deadline for Ford to serve amended invalidity -- Medius's contentions, but not
contentions later than 12/27/13
Deadline for the parties to substantially
complete their document productions, not
including electronic keyword searching of -- 11/22/13
individual custodians. Until the scope of such
electronic keyword searching of individual
custodians is resolved through agreement of
the parties or Court order, the documents of
any Ford deponent will be produced at least a
week in advance of their deposition. The
documents to be produced will be determined
through negotiation of counsel as to search
terms.
To be set by agreement of the
parties or order of the Court.
Deadline for Ford to produce documents -- Such production will be
lomitted from the 11/22/13 deadline complete before the close of
discovery
Deadline for Ford to present all 30(b)(6)
witnesses -- 12/20/13
Deadline for Medius to present Dan Preston
and Pierce Lutter for deposition -- 12/20/13
Opening expert reports 12/9/13 1/10/14
Rebuttal expert reports 1/7/14 2/14/14
All motions related to fact discovery must be
filed 1/17/14 2/7/14
Expert depositions -- 2/24/14-3/7/14
Close of fact and expert discovery 2/18/14 3/7/14
Dispositive Motion (and DaubertMotion) 3/18/14 3/20/14
Deadline (motions
noted for (motions noted for 4/11/14)
4/11/14)
5/12/14 5/12/14
Motions in limine (motions
noted for (motions noted for 5/23/14)
5/23/14)
Agreed pretrial order, trial briefs, proposed
voir dire, and jury instructions due 5/27/14 5/27/14
Pretrial conference 6/2/14 6/2/14
Trial Begins 6/16/14 6/16/14
Source: Leagle
