`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`
`
`
`C.A. No. 20-1580 (LPS)
`
`
`
`)))))))))
`
`
`
`
`
`v.
`
`GUARDANT HEALTH, INC.,
`
`
`Plaintiff,
`
`
`FOUNDATION MEDICINE, INC.,
`
`
`Defendant.
`
`STIPULATION AND [PROPOSED] ORDER
`
`WHEREAS Plaintiff Guardant Health, Inc. filed a motion for a preliminary injunction
`
`(D.I. 7) (“Motion”) and supporting papers (D.I. 8-11); and
`
`WHEREAS the parties have agreed on a discovery and briefing schedule in conjunction
`
`with the Motion;
`
`IT IS HEREBY STIPULATED AND AGREED by the parties, subject to the approval of
`
`the Court, that the parties shall adhere to the following schedule:
`
`Event
`
`Parties to serve no more than 10 document requests directed to issues
`related to the Motion and declarations
`
`Parties to serve written responses and objections to the document requests
`
`Completion of document production
`
`Guardant to make Gregory Cooper and/or Daniel Simon available for
`depositions (if requested by Defendant Foundation Medicine, Inc.
`(“FMI”))
`
`FMI’s 25-page Answering Brief and Supporting Declarations
`
`FMI to make any supporting declarants or persons relied upon by the
`supporting declarants for depositions (if requested by Guardant)
`
`
`Deadline
`
`December 22, 2020
`
`January 5, 2021
`
`January 15, 2021
`
`January 25 – January
`29, 2021
`
`February 26, 2021
`
`March 8 – March 12,
`2021
`
`
`
`
`
`Case 1:20-cv-01580-LPS Document 18 Filed 12/23/20 Page 2 of 2 PageID #: 2808
`
`
`
`Guardant’s 15-page Reply Brief
`
`Preliminary Injunction Hearing
`
`
`
`March 19, 2021
`
`
`
`(At the Court’s
`convenience)
`
`
`
`
`
`
`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`
`/s/ Jeremy A. Tigan
`
`
`
`Karen Jacobs (#2881)
`Jeremy A. Tigan (#5239)
`Sarah Simonetti (#6698)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`kjacobs@mnat.com
`jtigan@mnat.com
`ssimonetti@mnat.com
`
`Attorneys for Defendant Foundation Medicine, Inc.
`
`
`
`
`
`
`
`
`
`
`FARNAN LLP
`
`/s/ Brian E. Farnan
`
`
`
`Brian E. Farnan (#4089)
`Michael J. Farnan (#5165)
`919 N. Market St., 12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`mfarnan@farnanlaw.com
`
`Attorneys for Plaintiff Guardant Health, Inc.
`
`
`December 23, 2020
`
`
`SO ORDERED this ____ day of _________________, 2020.
`
`
`
`
`J.
`
`2
`
`
`
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