The opinion of the court was delivered by: Hon. Howard R. Lloyd
JOINT STIPULATION REGARDING PROPOSED SCHEDULE ON MOTION FOR PROTECTIVE ORDER AND SCHEDULE RE: SAME REQUEST FOR EXPEDITED BRIEFING
IT IS HEREBY STIPULATED AND AGREED, by and between the parties to the above-captioned matter, and by and between their undersigned counsel that:
1. On March 18, 2008, the parties filed a Joint Case Management Conference ("JCMS") with the Court.
2. The JCMS stated that the parties would submit a proposed Stipulated Protective Order to the Court by May 15, 2008.
3. On May 15, 2008, the parties requested, and were granted, a two-week extension of time (to May 29, 2008) so that they could continue to negotiate the terms of the Stipulated Protective Order.
4. The parties have further discussed the provisions of a proposed Protective Order and reached an impasse with respect to one provision of the document. The disagreement concerns whether the protective order should grant HP the right to object to Plaintiff's ability and right to use a testifying or consulting expert to whom Plaintiff will provide HP's "highly confidential" information. The parties have reached an agreement as to all other terms. At this time, and due to limited nature of the dispute, the parties have agreed, subject to Court approval, to an expedited briefing schedule as follows:
(a) HP will file a motion regarding this matter by June 19, 2008;
(b) Plaintiff Nathan Nygren's response to that motion will be due June 26, 2008; and
(c) A hearing, if the Court deems one necessary, will be held on July 1, 2008.
5. Neither parties' brief will exceed three pages.
6. The filer of this document attests that concurrence in the filing of this document has been obtained form the other signatory.
MORGAN, LEWIS & BOCKIUS LLP Barry L. McCoy (pro hac vice) Attorneys for Defendant HEWLETT-PACKARD COMPANY
LEVY, RAM & OLSON EDELSON & ASSOCIATES, LLC SPECTOR, ROSEMAN & KODROFF, P.C Michael F. Ram ...