Free Proposed Order - District Court of Delaware - Delaware

Case 1:06-cv-00788-JJF Document 130-2 Filed O1/24/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PROMOS TECHNOLOGIES, INC., )
Plaintiff, I
v. I C.A. No. 06-788 (JJF)
FREESCALE SEMICONDUCTOR, INC., l
Defendant. g
STIPULATED ORDER EXTENDING THE DISCOVERY DEADLINE
On January 8, 2008, Defendant Freescale Semiconductor, Inc., ("Freescale") moved for
an extension of the discovery deadline until February 29, 2008. Each of the parties submitted
letters to the Court, in which they stated their positions regarding Freescale’s motion for an
extension. On January 17, 2008, Freescale and Plaintiff, ProMOS Technologies, Inc.
("ProMOS") participated in a telephonic hearing on the issue before Special Master Vincent
Poppiti, during which each party was given the opportunity to be heard. During the telephonic
hearing, agreement was reached by the parties regarding disposition of Freescale’s Motion for
Extension of the Discovery Deadline.
Based on the Stipulation of the parties, after reviewing and considering the parties’
submissions related to Freescale’s motion, the Court being otherwise fully advised and good
cause having been shown;
IT IS HEREBY ORDERED
I. The current discovery deadline, January 21, 2008, is extended until February 1,
2008 for the purpose of permitting further discussions among the parties and the Special Master
and for a determination by the Special Master of the schedule for the completion of discovery.
The parties will provide status reports by telephone to Special Master Poppiti on January 24,
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Case 1:06-cv-00788-JJF Document 130-2 Filed O1/24/2008 Page 2 of 2
2008 at 5:30 p.m. and on February l, 2008 at 2:30 p.m. EST. Between the date of this Order and
February l, 2008, the parties will diligently work to schedule outstanding depositions and
complete document production in this matter;
2. Freescale will produce the following types of documents: schematics for any
custom library elements or design schematics (but not standard cell library schematics); high
level documents, such as microarchitecture documents on both the core and a product-level
basis, market requirement documents, product requirement documents, and architectural
definition documents; testing documents, such as verification plans, on both the core level and
product level; and, any additional design presentations that Freescale can locate after a
reasonable and thorough search on both the core level and a product level. For the products
accused of infringement in this matter as of the date of this Order, Freescale will make a rolling
production of these documents and will make a good-faith effort to complete this production by
not later than January 31, 2008. To the extent that additional documents come to Freescale’s
attention, Freescale will produce them promptly thereafter.
ENTERED this
24th day of January, 2008
Special Master
SO ORDERED this ; day of , 2008.

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