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Shum v. Intel Corp.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION


August 8, 2008

FRANK T. SHUM, PLAINTIFF,
v.
INTEL CORPORATION, JEAN-MARC VERDIELL AND LIGHTLOGIC, INC., DEFENDANTS.

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;

Protective Order;

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 defendants to file oppositions to Shum's motions in limine relating to defendants' expert reports served on the dates specified above may be extended from October 17, 2008 to October 24, 2008; and

WHEREAS, allowing the dates of expert discovery to be extended as set forth immediately above will not affect any of the other pretrial dates, including the November 3, 2008 trial date.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED among Shum and defendants, by and through their respective counsel, that:

2. Shum is to complete his depositions (if any) of Intel and Verdiell by August 22,

3. Shum's expert reports may be served on or before September 2, 2008;

5. The expert discovery cut-off date may be extended to October 17, 2008;

6. Shum's motions in limine (if any) relating to defendants' expert reports to be served on October 2 may be filed on or before October 20, 2008; and 21

7. Defendants' oppositions to Shum's motions in limine relating to the defendants' 22 expert reports specified hereinabove may be filed on or before October 24, 2008.

Dated: August 7, 2008 TAYLOR & COMPANY LAW OFFICES, LLP 24 25 Jessica L. Grant Attorneys for Defendants INTEL CORPORATION, LIGHTLOGIC, INC. and JEAN-MARC VERDIELL

1. Defendants are to complete their document production by August 15, 2008; 2008;

4. Defendants' expert reports may be served on or before October 2, 2008;

Dated: August 7, 2008 TOWNSEND AND TOWNSEND AND CREW LLP Angus M. MacDonald Attorneys for Plaintiff FRANK T. SHUM

IT IS SO ORDERED.

I, Jessica L. Grant, am the ECF User whose identification and password are being used to file the Stipulation and [Proposed] Order Regarding Expert Discovery Deadlines. I hereby attest that Angus M. MacDonald has concurred in this filing.

20080808

© 1992-2008 VersusLaw Inc.



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