`
`Case 1:20-cv—01580-LPS Document 18 Fited 12/23/20 Page 1 of 2 PageID #: 2807
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GUARDANT HEALTH, INC,
`
`Plaintiff,
`
`v.
`
`FOUNDATION MEDICINE, INC.,
`
`Defendant.
`
`vvwvvvvvv
`
`CA. No. 20—1580 (LPS)
`
`STIPULATION AND IPROPOSEDI ORDER
`
`WHEREAS Plaintiff Guardant Health, Inc. filed a motion for a preliminary injunction
`
`(DJ. 7) (“Motion”) and supporting papers (D1. 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:
`
`
`
`Parties to serve no more than 10 document requests directed to issues
`related to the Motion and declarations
`
`I
`
`December 22, 2020'
`
`Parties to serve written responses and objections to the document requests
`
`January 5, 2021
`
`2021
`
`Completion of document production
`
`Guardant to make Gregory Cooper and/or Daniel Simon available for
`depositions (if requested by Defendant Foundation Medicine, Inc.
`(“FMI”))
`
`January 15, 2021
`
`January 25 — January
`29, 2021
`
`FMI’S 25-page Answering Brief and Supporting Declarations
`
`February 26, 2021
`
`FMI to make any supporting declarants or persons relied upon by the
`supporting declarants for depositions (if requested by Guardant)
`
`March 8 -— March 12,
`
`
`
`Case 1:20-cv-01580-LPS Document 19 Filed 01/04/21 Page 2 of 2 PagelD #: 2810
`
`Case 1:20~cv—01580-LPS Document 18 Filed 12/23/20 Page 2 of 2 PagelD #: 2808
`
`Guardant’s 15-page Reply Brief
`
`March 19, 2021
`
`Preliminary Injunction Hearing
`
`a“ V1130
`(At1211: Court’s
`
`)2
`
`convenience)
`
`FARNANLLP
`
`MORRIS,NICHOLS, ARSHT &TUNNELL LLP
`
`1/){2% A ”j
`
`/3/ 6311111: E. Tainan
`
`/S/jeremy}1. ‘Tigan
`
`Brian E. Faman (#4089)
`Michael I. Farnan (#5165)
`919 N. Market St, 12th Floor
`Wilmington, DE 19801
`(302) 777—0300
`bfarnan@famanlaw.com
`mfarnan@farnaniaw.com
`
`Arrorneysfor Plaintifi‘Guardant Health, Inc.
`
`Karen Jacobs (#2881)
`Jeremy A. Tigan (#5239)
`Sarah Simonetti (#6698)
`1201 North Market Street
`PO. Box 1347
`Wilmington, DE 19899
`(3 02) 65 8-9200
`kjacobs@mnat.com
`jtigan@mnat.com
`ssirnonetti@mnat.com
`
`Attorneysfor Defendant Foundation Medicine, Inc.
`
`December 23, 2020
`
`SO ORDERED this—
`
`
`
`
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