The opinion of the court was delivered by: Honorable Claudia Wilken United States District Court Judge
Kevin R. Martin (SBN 176853) PATTON MARTIN & SULLIVAN LLP 6600 Koll Center Parkway, Suite 250 Pleasanton, California 94566 Tel: 925-600-1800 Fax: 925-600-1802 email@example.com Attorneys for Plaintiff and Counterclaim Defendant JAMES P. VICE
JOINT STIPULATION TO EXTEND TIME OF DEADLINE DATES
ISSUED IN CASE AND ORDER
MANAGEMENT ORDER OF FEBRUARY 8, 2011
Pursuant to Civil L.R. 6.2, Plaintiff and Counterclaim Defendant JAMES P. VICE and Defendant and Counterclaim Plaintiff WOODLINE USA, INC. do hereby submit this Joint Stipulation Extending Case Management Order Deadline Dates Issued on February 8, 2011 for 21 an additional 60 days from the presently deadline dates.
The parties submit this Stipulation on the basis that the parties participated in the court-ordered Early Neutral Evaluation on May 5, 2011 , which was conducted later than originally 24 anticipated, and the parties are evaluating the results and considering settlement options and 25 believe with additional time the parties may likely resolve their issues.
Based on the foregoing, the parties respectfully request the Court grant an additional days for the parties to comply with the claim construction proceedings according to the patent 28 local rules; and complete all fact discovery, including expert discovery as required by the Court's
1. Completion of Fact Discovery from June 15, 2011 to August 15, 2011;
2. Disclosure of identities and reports of expert witnesses from July 1, 2011 to September 1, 2011;
3. Completion of Expert Discovery from August 3, 2011 to October 3, 2011; and
4. All other dates issued in the Court's Case Management Order of February 8, 2011 shall remain the same.
Having considered the parties request and Joint Stipulation To Extend Time of Deadline Dates issued in the Case Management Order of February 8, 2011, therefore, the Court hereby 4 orders that the deadline for the parties to complete all fact discovery, including expert discovery 5 as required by the Court's Case Management Order of February 8, 2011 is extended for 60 days 6 as follows: 7
1. Completion of Fact Discovery is August 15, 2011;
2. Disclosure of identities and reports of expert witnesses September 1, 2011;
3. Completion of Expert Discovery is October 3,2011;
4. Compliance with the Claim Construction Proceedings of the Patent Local Rules is ...