`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`v.
`
`
`
`
`
`
` C.A. No. 1:18-cv-01519-MN
`
`
`
`
`FINJAN LLC, a Delaware Limited Liability
`Company,
`
` Plaintiff,
`
`
`
`RAPID7, INC., a Delaware Corporation
`and RAPID7 LLC, a Delaware Limited
`Liability Company,
`
`
`
`
`
`
`
`
`Defendants.
`
`
`
`
`
`
`JOINT MOTION TO EXTEND TIME FOR SUBMISSION OF
`DEPOSITION DESIGNATIONS
`
`Plaintiff Finjan LLC and Defendants Rapid7, Inc. and Rapid7 LLC (collectively, “the
`
`Parties”), respectfully move the Court to extend the time by which the Parties are required to
`
`submit deposition designations.
`
`Trial in this matter is scheduled to begin on Monday, February 22, 2021, and the pretrial
`
`conference is set for Monday, February 8, 2021. D.I. 29 at ¶¶ 19, 21. The Court’s Scheduling
`
`Order requires the Parties to submit a Joint Proposed Final Pretrial Order in this matter on February
`
`1, 2021. D.I. 29 at ¶ 19. Pursuant to Local Rule 16.3(c), the Pretrial Order requires, for those
`
`witnesses a party intends to call to testify by deposition, “a list of deposition designations”. L.R.
`
`16.3(c)(7). In order to reduce the likelihood of the Parties designating, responding to, and
`
`objecting to deposition testimony that may become superfluous as the Parties crystallize their
`
`respective trial strategies, the Parties respectfully request that Court permit deposition designations
`
`in this matter to be exchanged as follows:
`
`
`
`The Parties shall exchange opening deposition designations three weeks prior to
`the first day of trial;
`
`
`
`Case 1:18-cv-01519-MN Document 247 Filed 12/29/20 Page 2 of 2 PageID #: 8992
`
`
`
`
`
`
`The Parties shall exchange counter-designations and objections to opening
`designations two weeks prior to the first day of trial; and
`
`The Parties shall exchange objections to counter-designations three days after
`counter-designations are exchanged.
`
`The Parties submit that the requested procedure for deposition designations will not impact the
`
`Court’s scheduled trial date or the submission of any outstanding objections that remain to be
`
`resolved, per the Court’s Preferences & Procedures for Civil Cases.
`
`
`
`Dated: December 29, 2020
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`FISH & RICHARDSON P.C.
`
`
`
`/s/ Susan E. Morrison
`Susan E. Morrison (#4690)
`222 Delaware Avenue, 17th Floor
`Wilmington, DE 19801
`Tel.: (302) 652-5070
`morrison@fr.com
`
`Counsel for Plaintiff Finjan LLC
`
`
`
`
`
`
`
`
`
`DUANE MORRIS LLP
`
`
`
`
`/s/ Richard L. Renck
`Richard L. Renck (#3893)
`222 Delaware Avenue, Suite 1600
`Wilmington, DE 19801
`Tel.: (302) 657-4900
`rlrenck@duanemorris.com
`
`Counsel for Defendants
`Rapid7, Inc. and Rapid7 LLC
`
`
`2
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
