`
`
`
`Exhibit A – Joint Proposed Case Schedule
`
`
`Current Deadline
`6/29/2020
`
`Event
`Substantial completion of document production;
`exchange of privilege logs
`Deadline to serve interrogatories, requests for
`admission, and Rule 30(b)(6) deposition notices
`Deadline to serve all other fact deposition notices
`Fact discovery closes
`Elm elects no more than 36 total claims and provides
`final infringement contentions
`Defendants’ responses to contention interrogatories
`related to infringement
`Defendants elect no more than 36 prior art
`references and provide final invalidity contentions
`Elm’s responses to contention interrogatories related
`to invalidity
`Opening expert reports
`Responsive expert reports
`Expert discovery closes
`Case dispositive and Daubert motions
`Responses to case dispositive and Daubert motions
`Replies to case dispositive and Daubert motions
`Hearing on pending dispositive and Daubert motions
`Rule 16 Conference
`Deadline for Elm to provide a draft pretrial order to
`all other parties
`
`Deadline for all other parties to provide Elm and
`each other party with their responses to Elm’s draft
`order
`Deadline for the parties to file a joint proposed
`statement setting forth their positions regarding trial
`sequencing and scheduling
`
`Pretrial conference
`First jury trial (second and third jury trial to be
`determined by the Court)
`Deadline for the parties to jointly submit a form of
`order to enter judgment on the verdict and to submit
`a joint status report (should they wish to file one),
`indicating among other things how the case should
`proceed and listing any post-trial motions each party
`intends to file
`
`
`
`
`
`
`Extended Deadline
`8/28/2020
`
`9/25/2020
`
`11/10/2020
`1/15/2021
`2/5/2021
`
`2/19/2021
`
`2/26/2021
`
`3/16/2021
`
`7/23/2020
`
`9/10/2020
`10/26/2020
`11/16/2020
`
`12/7/2020
`
`12/15/2020
`
`1/5/2021
`
`2/8/2021
`3/9/2021
`4/26/2021
`5/24/2021
`6/14/2021
`6/21/2021
`TBD
`TBD
`30 days before the
`pretrial order is to be
`filed with the Court
`14 days before the
`pretrial order is to be
`filed with the Court
`Third business day
`before the date of the
`Pretrial Conference
`(6 p.m. ET)
`TBD
`TBD
`
`4/6/2021
`5/3/2021
`6/1/2021
`6/21/2021
`7/12/2021
`7/19/2021
`TBD
`TBD
`30 days before the
`pretrial order is to be
`filed with the Court
`14 days before the
`pretrial order is to be
`filed with the Court
`Third business day
`before the date of the
`Pretrial Conference
`(6 p.m. ET)
`TBD
`TBD
`
`7 days after each jury
`verdict
`
`7 days after each jury
`verdict
`
`