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In Re Tft-Lcd (Flat Panel) Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


December 16, 2011

IN RE TFT-LCD (FLAT PANEL) ANTITRUST LITIGATION

The opinion of the court was delivered by: The Honorable Susan Illston Judge of the District Court

MELVIN R. GOLDMAN (CA SBN 34097) MGoldman@mofo.com STEPHEN P. FRECCERO (CA SBN 131093) SFreccero@mofo.com DEREK F. FORAN (CA SBN 224569) DForan@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522 Attorneys for Defendants Seiko Epson Corporation, Epson Imaging Devices Corporation, 8 and Epson Electronics America, Inc.

This Document Relates to: Motorola Mobility, Inc. v. AU Optronics Corporation, et al., C 09-5840 SI AT&T Mobility LLC, et al. v. AU Optronics Corp., et al., C 09-4997 SI Target Corp., et al. v. AU Optronics Corp., et al., Case No. CV-04945 SI Dell Inc. and Dell Products L.P. v. Sharp Corp. et al., Case No. CV 10-1064 SI

STIPULATION AND [PROPOSED] ORDER MODIFYING FACT DISCOVERY CUTOFF DATE AND EXTENSION OF TIME TO MOVE TO COMPEL

DataComm, Inc., Southwestern Bell Co., ("AT&T")*fn1 ; Target Corp.; Sears Roebuck and Co.; 4 Dell Products L.P.'s ("Dell") (collectively, "Plaintiffs") and Defendants Epson Imaging Devices 6 Corporation and Epson Electronics America, Inc. (collectively, "Epson Defendants") hereby 7 stipulate as follows: 8

State Attorney General Actions (Dkt. No. 3110, the "Scheduling Order"); 12 Admission To Epson Defendants on June 16, 2011; 15 Plaintiffs Motorola Mobility, Inc. ("Motorola"); AT&T Mobility, LLC, AT&T Corp., AT&T Services, Inc., Pacific Bell Telephone Company, AT&T Operations, Inc., AT&T 3 Kmart Corp.; Old Comp Inc.; Good Guys, Inc.; RadioShack Corp.; Newegg Inc.; Dell Inc., and 5

STIPULATION

WHEREAS discovery closes in this case on December 8, 2011, as set forth in the Stipulation and Order Modifying Pretrial Schedule for "Track One" Direct Action Plaintiff and 11

WHEREAS Plaintiffs Motorola and Dell served Direct Action Plaintiffs' First Set of Interrogatories To Epson Defendants and Direct Action Plaintiffs' First Set of Requests For 14

WHEREAS Plaintiffs served their Joint Set of Requests for Production of Documents and Interrogatories on Epson Defendants in the above-captioned cases on November 2, 2011; 17 18 outstanding discovery issues and are attempting to answer questions regarding their respective 19 data productions informally without the need for formal discovery; 20 21 of the close of fact discovery set forth in the Scheduling Order for the limited purposes identified 22 below; 23 24 and agree as follows: 25 26

WHEREAS Epson Defendants and Motorola continue to meet and confer over several

WHEREAS Plaintiffs and Epson Defendants have conferred and agreed to the extension

NOW, THEREFORE, the Parties, through their undersigned respective counsel, stipulate

1. Epson Defendants' deadline to respond to Plaintiffs' Joint Set of Requests for Production of Documents and Interrogatories shall be extended to December 19, 2011. 3

2. Plaintiffs' deadline to move to compel further responses to Plaintiffs' Joint Set of Requests for Production of Documents and Interrogatories shall be extended to January 6, 2012. 5

3. Epson Defendants' deadline to move to compel further responses from Motorola 6 with respect to the following discovery issues, shall be extended to January 31, 2012: 7

a. Further responses to Defendants' Third Set of Requests for Production of Documents to Motorola, Inc., dated June 7, 2011, Nos. 6-8;

b. Further responses to Defendants' Second Set of Requests for Production of Documents to Plaintiff Motorola, Inc., dated Apr. 16, 2010, Nos. 1-5 and 8.

4. Motorola's deadline to move to compel further responses regarding the Epson Defendants' production of transaction data shall be extended to January 31, 2012. 13

5. Motorola and Dell's deadline to move to compel further responses from Epson Defendants with respect to the Direct Action Plaintiffs' First Set of Interrogatories To Epson 15

Defendants, Nos. 3-5, 38, and 50, and Direct Action Plaintiffs' First Set of Requests For 16 Admission To Epson Defendants, Nos. 14-24, 54-63, 66-74, and 79-95, shall be extended to 17 January 31, 2012. 18

IT IS SO ORDERED.

ATTESTATION: Pursuant to N.D. Cal. General Order 45, Part X-B, the filer attests that 7 concurrence in the filing of this document has been obtained from each signatory hereto. 8 9

Dated: December 13, 2011

By: /s/ Derek Foran

Derek Foran


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