`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB ASSETS, LLC,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., AMAZON.COM LLC,
`AMAZON WEB SERVICES, INC., A2Z
`DEVELOPMENT CENTER, INC. d/b/a LAB126,
`RAWLES LLC, AMZN MOBILE LLC, AMZN
`MOBILE 2 LLC, AMAZON.COM SERVICES, INC.
`f/k/a AMAZON FULFILLMENT SERVICES, INC.,
`and AMAZON DIGITAL SERVICES LLC,
`
`Defendants.
`
`C.A. No. 1:19-cv-01410-MN
`
`JOINT STIPULATION AND ORDER
`
`WHEREAS, on May 20, 2022, this Court entered an Order amending the Scheduling Order
`
`in this action, including setting a fact discovery deadline of June 24, 2022;
`
`WHEREAS, multiple depositions were postponed and rescheduled due to health issues,
`
`including COVID-19 infection, of both witnesses and counsel;
`
`WHEREAS, on June 27, 2022, the Court entered an order permitting the parties to take
`
`certain depositions outside of fact discovery (see D.I. 169);
`
`WHEREAS, the parties, notwithstanding the June 24, 2022 close of fact discovery (see
`
`May 20, 2022 Order), agreed to complete, and did complete, the deposition of Marco Petroni on
`
`July 5, 2022; and
`
`WHEREAS, as result of these depositions having been taken outside of fact discovery, and
`
`because a discussion during the deposition of Rino Caruccio on June 29, 2022 resulted in an
`
`agreement that Defendants will produce additional financial information that is relevant to
`
`Plaintiff’s opening expert reports;
`
`1
`
`
`
`Case 1:19-cv-01410-MN Document 172 Filed 07/12/22 Page 2 of 3 PageID #: 2626
`
`
`
`IT IS HEREBY STIPULATED AND AGREED, subject to the approval and Order of the
`
`Court, that:
`
`(1) Notwithstanding the June 24, 2022 close of fact discovery (see May 20, 2022 Order),
`
`the deposition of Marco Petroni, which the parties completed on July 5, 2022, shall be treated for
`
`all purposes as if it was conducted within the fact discovery period; and
`
`(2) The deadlines in the Court’s May 20, 2022 Order shall be amended as set forth in the
`
`below table:
`
`Existing
`Deadline
`7/22/2022
`8/25/2022
`9/16/2022
`10/7/2022
`11/4/2022
`12/2/2022
`12/23/2022
`
`TBD
`
`TBD
`TBD
`
`
`
`Proposed
`Deadline
`8/15/2022
`9/15/2022
`10/7/2022
`11/11/2022
`12/9/2022
`1/20/2023
`2/10/2023
`
`TBD
`
`TBD
`TBD
`
`Event / Deadline
`
`Opening expert reports
`Rebuttal expert reports
`Reply expert reports
`Expert discovery closes
`Case-dispositive motions and Daubert motions
`Response to dispositive motions and Daubert motions
`Reply to dispositive motions and Daubert motions
`File (i) proposed voir dire, (ii) preliminary jury
`instructions, (iii) final jury instructions, (iv) special
`verdict forms
`Pretrial conference
`Jury Trial (7 days)
`
`The undersigned counsel hereby certify that they provided a copy of this stipulation to their
`
`clients in compliance with District of Delaware Local Rule 16.4(b).
`
`
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 172 Filed 07/12/22 Page 3 of 3 PageID #: 2627
`
`WILSON SONSINI GOODRICH & ROSATI
`
`ASHBY & GEDDES
`
`/s/ Ian R. Liston
`
`/s/ Andrew C. Mayo
`
`Ian R. Liston (#5507)
`Jennifer A. Ward (#6476)
`222 Delaware Avenue, Suite 800
`Wilmington, DE 19801
`iliston@wsgr.com
`jward@wsgr.com
`Telephone: (302) 304-7600
`
`Of Counsel:
`
`Edward G. Poplawski, admitted pro hac vice
`Erik J. Carlson, admitted pro hac vice
`Ryan S. Benyamin, admitted pro hac vice
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071-2027
`epoplawski@wsgr.com
`ecarlson@wsgr.com
`rbenyamin@wsgr.com
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`
`James C. Yoon, admitted pro hac vice
`Ryan Smith, admitted pro hac vice
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`jyoon@wsgr.com
`rsmith@wsgr.com
`Telephone: (650) 493-9300
`Facsimile: (650) 493-6811
`
`Attorneys for VB Assets, LLC
`
`SO ORDERED this 12th day of July 2022.
`
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`Telephone: (302) 654-1888
`
`Of Counsel:
`
`J. David Hadden, CSB No. 176148
`Email: dhadden@fenwick.com
`Saina S. Shamilov, CSB No. 215636
`Email: sshamilov@fenwick.com
`Ravi R. Ranganath, CSB No. 272981
`rranganath@fenwick.com
`Johnson Kuncheria, CSB No. 335765
`jkuncheria@fenwick.com
`Vigen Salmastlian, CSB No. 276846
`Email: vsalmastlian@fenwick.com
`Sapna Mehta, CSB No. 288238
`Email: smehta@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone: 650.988.8500
`Facsimile: 650.938.520
`
`Attorneys for Defendants Amazon.com, Inc.,
`Amazon.com LLC, Amazon Web Services, Inc., A2Z
`Development Center, Inc. d/b/a Lab126, Rawles LLC,
`AMZN Mobile LLC, AMZN Mobile 2 LLC,
`Amazon.com Services, Inc. f/k/a Amazon Fulfillment
`Services, Inc., and Amazon Digital Services LLC
`
`________________________________
`The Honorable Maryellen Noreika
`United States District Judge
`
`3
`
`
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
