The opinion of the court was delivered by: Honorable D. Lowell Jensen United States District Court Judge
STIPULATION AND [PROPOSED] ORDER REGARDING EXPERT DISCOVERY DEADLINES
TAYLOR & CO. LAW OFFICES, LLP
WHEREAS, on April 3, 2008, this Court entered an Amended Order for Pretrial Preparation setting the dates for: (1) the parties to complete fact discovery by July 28, 2008, (2) plaintiff Frank T. Shum ("Shum") to serve expert reports by August 1, 2008, (3) defendants Intel "Defendants") to serve expert reports by September 5, 2008, (4) the close of expert discovery on October 3, 2008, (5) the parties to file motions in limine by October 10, 2008, and (6) the parties to file oppositions to motions in limine by October 17, 2008;
Expert Discovery Deadlines (Docket No. 608) for: (1) Shum to serve expert reports by August 8, 2008, (2) Intel, Verdiell and LightLogic to serve expert reports by September 12, 2008, and (3) the close of expert discovery on October 8, 2008;
WHEREAS, defendants are in the process of completing additional fact discovery pursuant 13 to Magistrate Judge Chen's Order Re Hearing On July 23, 2008 (Docket No. 604);
WHEREAS, on August 1, 2008, defendants filed a Motion for Protective Order (Docket 16 WHEREAS, a hearing has not yet been conducted on defendants' pending Motion for
WHEREAS, pursuant to Magistrate Judge Chen's guidance, counsel for the parties continue to meet and confer about the conclusion of fact discovery, including the scope and timing of depositions (if any);
WHEREAS, other than the outstanding issues enumerated in this Stipulation and discovery relating to Ernst & Young, fact discovery is closed;
WHEREAS, counsel for Shum and counsel for defendants agree that: (1) the date for defendants to complete production of documents pursuant to Magistrate Judge Chen's Order Re Shum to complete his additional depositions (if any) of Intel and Verdiell may be extended to 1.
Corporation ("Intel"), Jean-Marc Verdiell ("Verdiell") and LightLogic, Inc. (collectively 5
WHEREAS, on July 31, 2008, this Court entered a Stipulation and Order Regarding
WHEREAS, on July 11, 2008, Shum served Notices of Deposition on Intel and Verdiell; No. 609) to prevent the noticed depositions of Intel and Verdiell from being taken;
Hearing on July 23, 2008 (Docket No. 604) may be extended to August 15, 2008; (2) the date for 27 August 22, 2008; (3) the date for Shum to serve his expert reports may be extended from August 8, 2008 to September 2, 2008; (4) the date for defendants to serve their expert reports may be extended from September 12, 2008 to October 2, 2008; (5) the date for the close of expert discovery may be extended from October 8, 2008 to October 17, 2008; (6) the date for Shum to file motions in limine (if any) relating to defendants' expert reports served on the dates specified above may be extended from October 10, 2008 to October 20, 2008, (7) the dates for Shum to file all other motions in limine remains unchanged, and (8) the date for ...