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 United States District Court
CHRISTOPHER A. NEDEAU (SBN 81297) firstname.lastname@example.org 2 CARL L. BLUMENSTEIN (SBN 124158) email@example.com 3 JAMES A. NICKOVICH (SBN 244969) 4 firstname.lastname@example.org NOSSAMAN LLP 5 50 California Street, 34th Floor San Francisco, CA 94111-4624 6 Telephone: (415) 398-3600 Facsimile: (415) 398-2438 7 Attorneys for Defendants 8 AU Optronics Corporation and 9 AU Optronics Corporation America
STATE OF MISSOURI, ex rel.
Chris Koster, Attorney General, et al.,
STATE OF ARKANSAS, ex rel.
Case No. 3:10-cv-03619 SI
Dustin McDaniel, Attorney General, et al.,
STATE OF MICHIGAN, ex rel. STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF TIME ON DEADLINES IN CASE SCHEDULE
Bill Schuette, Attorney General, et al.,
STATEOFWESTVIRGINIA, ex rel.
Darrell McGraw, Attorney General, et al., 20 20 ex rel.
J.B. Van Hollen, Attorney General, et al. 22 22
STATE OF WISCONSIN STATE OF FLORIDA, OFFICE OF THE Case No. 3:10-cv-03517 SI 23 23 ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, 24 24 25 25 Plaintiff, v. 26 26 AU OPTRONICS CORPORATION, et al. 27 27 Defendants.
America (collectively, "AUO"), LG Display Co., Ltd. and LG Display America, Inc. (collectively, "LG 4 Display")(AUO and LG Display collectively, the "5-States Defendants"), wish to extend certain 5 deadlines entered in the Court's July 14, 2011 Modifying Pretrial Schedule for Track One DAPs and AG 6 WHEREAS, the State of Florida (the "Florida Plaintiff") and Toshiba Corporation, Toshiba Mobile Display Co., Ltd., Toshiba America Electronic Components, Inc., Toshiba America Information 9 "Defendants") wish to extend certain deadlines entered in the Court's July 14, 2011 Modifying Pretrial 11 Case No. 3:10-cv-03517, only; 13 14 the Defendants have negotiated in good faith regarding temporary extensions for certain fact and expert 15 discovery deadlines, and wish to achieve a global resolution extending outstanding deadlines for 16 motions to compel fact discovery, expert discovery and reports, and dispositive motions and related 17 briefing, 21 will be moved from December 8, 2011 to January 10, 2012. The parties maintain all objections and 22 defenses in responding to fact discovery that they would have had in the absence of this stipulation. This 23 stipulation will not preclude subpoenaed non-parties from producing responsive documents and 24 information after January 10, 2012. 25
26 current fact discovery cut-off date of December 8, 2012 (e.g., issuance of new written discovery 27 requests, new nonparty subpoenas, more depositions, etc.). If there are particular state-specific issues 28 (such as the Wisconsin deposition currently scheduled for December 21, 2012), then those issues may be
WHEREAS, the States of Missouri, Arkansas, West Virginia, Michigan, and Wisconsin (collectively, the "5-States Plaintiffs")and AU Optronics Corporation and AU Optronics Corporation 3 Cases (Dkt No. 3110) for the purposes of the 5-States action, Case No. 3:10-cv-03619; 7 8 Systems, Inc. (collectively, the "Toshiba Entities"), and the 5-States Defendants (collectively, the 10 Schedule for Track One DAPs and AG Cases (Dkt No. 3110) for the purposes of the Florida action, 12
WHEREAS, the 5-States Plaintiffs and the Florida Plaintiff (collectively, the "States") as well as
WHEREAS, the States and the Defendants intend to keep the November 5, 2012 trial date;
NOW THEREFORE, the parties stipulate and agree as follows:
1. The States' and the Defendants' mutual deadline for responding to pending fact discovery
2. This stipulation does not allow new fact discovery of any sort to be served beyond the worked out separately among the affected parties. Any such individual, state-specific stipulations 2 regarding fact discovery between the States and the Defendants would take priority over this stipulation. 3 4 to compel or otherwise seeking judicial intervention with respect to disputes about the pending 5 discovery requests after January 10, 2012.
3. The new period for completing fact discovery does not preclude the parties from moving
4. All of the current deadlines as to the States and the Defendants in the Court's July 14, 2011 Modifying Pretrial Schedule for Track One DAPs and AG Cases (Dkt No. 3110), with the 8 exception of the deadlines for the Pretrial Conference and Trial, are extended 30 days.
Attestation: Pursuant to General Order 45, Part X-B, the filer attests that concurrence in the 22 filing of this document have been obtained from each of the signatories. 23
IT IS SO ORDERED.
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