`
`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`IRELL & MANELLA LLP
`Jonathan S. Kagan (SBN 166039)
`jkagan@irell.com
`Alan Heinrich (SBN 212782)
`aheinrich@irell.com
`Joshua Glucoft (SBN 301249)
`jglucoft@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile: (310) 203-7199
`
`Rebecca Carson (SBN 254105)
`rcarson@irell.com
`Ingrid M. H. Petersen (SBN 313927)
`ipetersen@irell.com
`Kevin Wang (SBN 318024)
`kwang@irell.com
`840 Newport Center Drive, Suite 400
`Newport Beach, California 92660-6324
`Telephone: (949) 760-0991
`Facsimile: (949) 760-5200
`
`Attorneys for Defendant
`JUNIPER NETWORKS, INC.
`
`
`
`
`
`
`
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`FINJAN, INC.,
`
`Plaintiffs,
`
`v.
`
`
`JUNIPER NETWORKS, INC.,
`
`Defendant.
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`)
`Case No. 3:17-cv-05659-WHA
`)
`
`)
`STIPULATION TO EXTEND DEADLINE FOR
`)
`OPENING AND REBUTTAL EXPERT REPORTS
`)
`
`)
`Hon. William H. Alsup
`)
`
`)
`Trial Date: July 29, 2019
`)
`Current Opening Expert Report Date: April 30, 2019
`)
`New Opening Expert Report Date: May 18, 2019
`)
`New Rebuttal Expert Report Date: June 17, 2019
`)
`
`
`
`
`
`
`
`
`STIPULATION TO EXTEND DEADLINE FOR OPENING EXPERT REPORTS
`(Case No. 3:17-cv-05659-WHA)
`
`
`
`10672186
`
`
`
`
`
`Case 3:17-cv-05659-WHA Document 453 Filed 04/26/19 Page 2 of 3
`
`Plaintiff Finjan, Inc. (“Finjan”) and Defendant Juniper Networks, Inc. (“Juniper”), hereby
`stipulate as follows:
`WHEREAS, the Court has set trial regarding Juniper’s equitable defenses and/or
`counterclaims related to U.S. Patent No. 8,677,494 (“the ‘494 Patent”) that were not rendered
`moot in light of the jury’s verdict for July 29, 2019 (Dkt. No. 348);
`WHEREAS, under Federal Rule of Civil Procedure 26, opening expert reports for the July
`trial are due by April 30, 2019;
`WHEREAS, a deposition related to the July trial is scheduled to occur on May 15, 2019;
`WHEREAS, Finjan and Juniper have agreed to extend the deadline for opening expert
`reports until May 18, 2019 in order to account for the May 15, 2019 deposition;
`WHEREAS, Finjan and Juniper have agreed rebuttal reports will be due June 17th;
`WHEREAS, the stipulated extension of time set forth herein will not alter the date of any
`event or other deadline already fixed by Court order;
`NOW, THEREFORE, by and through their respective counsel of record, the parties hereby
`stipulate and agree as follows:
`• All opening expert reports regarding Juniper’s equitable defenses and/or counterclaims
`related to the ‘494 Patent that were not rendered moot in light of the jury’s verdict shall
`be due by May 18, 2019; and
`• All rebuttal expert reports shall be due by June 17, 2019.
`IT IS SO STIPULATED.
`Dated: April 25, 2019
`
`
`
`
`
`
`
`
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`By: /s/ Paul Andre
`
`
`
` Paul Andre
` Attorneys for Plaintiff, FINJAN, INC.
`
`
`Dated: April 25, 2019
`
`
`
`
`
`
`
`
`IRELL & MANELLA LLP
`By: /s/ Rebecca Carson
` Rebecca Carson
` Attorneys for Defendant, JUNIPER NETWORKS, INC.
`
`
`
`
`
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`- 1 -
`STIPULATION TO EXTEND DEADLINE FOR OPENING EXPERT REPORTS
`(Case No. 3:17-cv-05659-WHA)
`
`
`
`10672186
`
`
`
`
`
`Case 3:17-cv-05659-WHA Document 453 Filed 04/26/19 Page 3 of 3
`
`[PROPOSED] ORDER
`Pursuant to the stipulation of the parties, it is hereby ORDERED that all opening expert
`reports regarding Juniper’s equitable defenses and/or counterclaims related to the ‘494 Patent that
`were not rendered moot in light of the jury’s verdict shall be due by May 18, 2019 and rebuttal
`expert reports shall be due by June 17, 2019.
`PURSUANT TO STIPULATION IT IS SO ORDERED.
`
`
`Dated: ___________________________
`
`
`
`
`Hon. William H. Alsup
`United States District Court Judge
`
`
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`[PROPOSED] ORDER EXTENDING DEADLINE FOR OPENING EXPERT REPORTS
`(Case No. 3:17-cv-05659-WHA)
`
`
`
`10672186
`
`
`
`
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