Free Stipulation - District Court of Delaware - Delaware

Case 1 :07-cv-00017-GIVIS Document 80 Filed O4/O3/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
I FOR THE DISTRICT OF DELAWARE
KEURIG, INCORPORATED,
Plaintiff,
V' Civil Action No. 07-0 1 7-GMS
KRAFT FOODS GLOBAL, INC.,
TASSIMO CORPORATION, and
KRAFT FOODS INC.,
i Defendants.
STIPULATION AND PROPOSED ORDER FOR AMENDMENT OF THE
SCHEDULING ORDER
IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel
for the parties, and subject to the approval of the Court, that because of discovery issues both
parties request a one—week extension to serve their expert reports.
Plaintiff, with the assent of Defendants, requests a one-week extension of the deadline for
p serving its opening expert report on damages because Defendants are currently in the midst of
locating and producing certain financial data responsive to Plaintiffs' discovery requests that will
be addressed in Plaintiffs damages expert's report. Counsel for the parties are working
cooperatively to efficiently manage the final phase of this written discovery as it relates to expert
reports.
Defendant, with the assent of Plaintiff, requests a one-week extension to serve its
_ technical expert reports because overseas technical fact discovery was just completed and an
additional week is needed to complete the reports.
DB02:6714784.1 0659271001

Case 1 :07-cv—OOO17-GIVIS Document 80 Filed O4/O3/2008 Page 2 of 3
The parties agree that all expert reports should be kept on the same schedule, and
accordingly propose that the Scheduling Order dated July 17, 2007 (D.I. 34) and amended on
March 5, 2008 (D.1. 58) shall be amended as follows:
EVENT ORIGINAL DATE CURRENT PROPOSED DATE
DATE
Opening Expert February 1, 2008 April 8, 2008 April 15, 2008
Reports
Answering Expert March 3, 2008 May 6, 2008 May 13, 2008
Re orts -
Close of Expert April 1, 2008 May 20, 2008 May 27, 2008
Discovery
All remaining dates in the Scheduling Order (D.1. 34), including those for summary
judgment letter briefing, remain in full force and effect.
/s/ Karen E. Keller /s/ Richard L. Horwitz
John W. Shaw (No. 3362) Richard L. Horwitz (No. 2246)
Karen E. Keller (No. 4489) David E. Moore (No. 3983)
YOUNG CONAWAY STARGATT & POTTER ANDERSON &
TAYLOR, LLP CORROON LLP
The Brandywine Building Hercules Plaza, 6th Floor
1000 West Street, 17m Floor 1313 N. Market Street
Wilmington, DE 19801 Wilmington, DE 19801
(302) 571-6600 (302) 984-6000
[email protected] [email protected]
Michael A. Albert David M. Schlitz
Michael N. Rader William S. Foster, Jr.
Laura Topper C. John Brown
Gerald B. Hrycyszyn BAKER BOTTS L.L.P.
WOLF, GREENFIELD & SACKS, P.C. 1299 Pennsylvania Ave., N.W.
600 Atlantic Avenue Washington, D.C. 20004-2400
Boston, MA 02210 (202) 639-7700
(617) 646-8000 [email protected]
[email protected]
. Attorneys for Plaint@’Keurig_5 Incorporated Attorneys for T assimo Corporation, Krajt
Foods Global, [nc. and Krajt Foods Inc.
DB02:67l4784.1 2 065927.100l

Case 1:07-cv—OOO17-G|\/IS . Document 80 Filed O4/O3/2008 Page 3 of 3
ORDER
IT IS SO ORDERED this day of April, 2008.
United States District Court Judge
3
1;>B02;67147s4.1 065927.100l