Free Stipulation to EXTEND Time - District Court of Delaware - Delaware

Case 1 :04-cv-00960-SLR Document 73 Filed O1/30/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LSQUARED TECHNOLOGIES, INC., a )
Canadian corporation, and LSQUARE )
TECHNOLOGIES (OREGON) INC., an )
Oregon corporation, )
Plaintiffs, )
v. ) CA. No. 04~CV—960-SLR
I
MOTOROLA, INC., a Delaware )
corporation, )
Defendant. )
JOINT STIPULATION AND ORDER TO AMEND
DISCOVERY CUTOFF AND EXPERT DISCLOSURE HEADLINES
The parties have agreed to submit this dispute to private mediation in February
2006. Accordingly, the parties irereby stipulate, subject to approval of the Court, to
amend several pretrial deadlines, but not the trial date or the deadline for dispositive
motions.
First, the parties seek to amend the discovery deadline imposed by the Conrt’s
Order dated November I4, 2005 (DI. 46). That Order granted the parties’ joint request
to extend the discovery cutoff to ]?·`ebruar·y I5, 2006. The parties now jointly seek an
extension to April 3, 2006. This is to accommodate depositions that were to be taken at
the very end of this month and in early February; the parties believe that the prospects of
settlement will be increased by postponing the depositions until, if necessary, after the
mediation.
The parties also seek to amend the expert disciosure deadlines imposed in
paragraph 2(g) ofthe Court’s June 3, 2005, Scheduling Order (DI. 24). That paragraph
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Case 1:04-cv-00960-SLR Document 73 Filed O1/30/2006 Page 2 of 3
provides, "Reports from retained experts under Rule 26(a)(2) on issues for which any
party has the burden of proof due by February 1, 2006. Rebuttal expert reports (including
expert reports on which party does not have the burden ofproot) due by March 17,
2006." The parties jointly seek an extension to March 1, 2006 for the expert disclosure
deadline and to April 3, 2006 for the rebuttal expert disclosure deadline. The parties also
stipulate that any depositions of rebuttal experts may take place after April 3, 2006.
All other dates set out in the Court’s June 3, 2005, Scheduling Order remain
unchanged,
YOUNG CONAWAY STARGATT & TAYLOR, LLP
MW/A
William W. Bowser (Bar LD. 2239)
The Brandywine Building
1000 West Street, 17th Floor
Wilmington, Delaware l9801
Telephone: (302) 57l—6601; Facsimile: (302) 576—.3282
OF COUNSEL:
Randy Papetti, Richard A. Halloran, Cory A. Talbot
Lewis and Roca LLP
40 N. Central Avenue
Phoenix, Arizona 85004
Telephone: (602) 262-531 l
Attorneys for Defendant
"
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S LD. 4072)
David A. Felice (Bar LD. 4090)
1201 North Market Street, Suite 1400
Wilmington, DE 1980l
Telephone: (302) 295-2000; Facsimile: (302) 295-2013
OF COUNSEL:
Kevin F. Berry
Cozen O‘Connor
1900 l\/Iarket Street
Philadelphia, PA 19103
Attorneys for Plaintiff
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Case 1:04-cv-00960-SLR Document 73 Filed O1/30/2006 Page 3 of 3
IT IS SO ORDERED this day of , 20060.
Chief Judge Sue L. Robinson
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