Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 1 of 14 PageID #: 835
`
`IN THE UNITED STATES DISTRICT
`COURT
`FOR THE DISTRICT
`OF DELAWARE
`
`v.
`
`TIMES FIBER COMMUNICATIONS,
`INC., )
`)
`Plaintiff, )
`(VAC) (MPT)
`) C.A. No. 21-1823
`)
`)
`)
`Defendant. )
`
`PPC BROADBAND,
`INC.,
`
`SCHEDULING ORDER
`
`This �f.k.li ay of May 2022, the Cottrt lutvittg
`ooRdncted
`ao initial
`Rule 16 1,ch@0Mliftg
`aoo
`
`p!auoiog canfei:ence
`.pmsuaor ta 1 ocal Rule
`) 6 1 au May 9. 2022, �ptj the parties
`having
`
`determined after
`discussion
`that the matter
`cannot be resolved
`at this juncture
`by settlement,
`
`voluntary
`mediation,
`or binding
`arbitration;
`
`IT IS ORDERED that:
`
`Except
`as otherwise
`specified
`herein,
`any application
`to
`1. Applications
`by Motion.
`
`the Court shall be by written
`motion.
`Any non-dispositive
`motion shall contain
`the statement
`
`required
`by Local Rule 7. I. I.
`
`2. Rule 26{a)(l) Initial Disclosures and E-Discovery
`Default Standard.
`Unless
`
`to by the parties, the parties
`shall make their initial
`disclosures
`pursuant
`to
`otherwise
`agreed
`
`26(a)( l) within
`(14) days of the date of this Order.
`If
`Federal
`Rule of Civil Procedure
`fourteen
`
`they have not already
`done so, the parties
`are to
`review
`the Court's
`Default Standard
`for Discovery,
`
`Discovery
`of Electronically
`Stored Information
`(''ESI"
`), which is posted at
`including
`
`https://www.ded.uscourts.gov/default-standard-discovery
`and is incorporated
`herein
`by reference.
`
`The parties
`shall make their disclosures
`pursuant
`to Paragraph
`3 of the Court's
`Default
`Standard
`
`for Discovery
`within
`(30) days of the date of this Order.
`thirty
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 2 of 14 PageID #: 836
`
`3.
`
`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
`
`parties, and to amend or supplement the pleadings shall be filed on or before March 30, 2023.
`
`4.
`
`Application to Court for Protective Order. Should counsel find it will be necessary
`
`to apply to the Court for a protective order specifying terms and conditions for the disclosure of
`
`confidential information, counsel should confer and attempt to reach an agreement on a proposed
`
`form of order and submit it to the Court within thirty (30) days from the date of this Order. Should
`
`counsel be unable to reach an agreement on a proposed form of protective order, counsel must
`
`follow the provisions of 17(g) below.
`
`Any proposed protective order should include the following paragraph:
`
`Other Proceedings. By entering this order and limiting the disclosure
`of information in this case, the Court does not intend to preclude
`another court from finding that information may be relevant and
`subject to disclosure in another case. Any person or party subject to
`this order who becomes subject to a motion to disclose another
`party's information designated "confidential" [the parties should list
`any other level of designation, such as "highly confidential," which
`may be provided for in the protective order] pursuant to this order
`shall promptly notify that party of the motion so that the party may
`have an opportunity to appear and be heard on whether that
`information should be disclosed.
`
`5.
`
`Courtesy Copies. This matter has been assigned to a vacant judgeship, designated
`
`"V AC" on the docket. The parties have not consented to the jurisdiction of a magistrate judge.
`
`Pursuant to 1 5 of Standing Order 2022-VAC-1 (dated March 9, 2022) or 1 3 of Standing Order
`
`2022-3 (dated March 16, 2022), this matter is referred to this Judge for limited purposes. For the
`
`pleadings and all matters within the scope of the referral to this Judge, the parties shall provide the
`
`Court two (2) courtesy copies of all briefs and any other document filed in support of any briefs
`
`(i.e., appendices, exhibits, declarations, affidavits, etc.). This provision also applies to papers filed
`
`under seal. All courtesy copies shall be single-sided.
`
`2
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 3 of 14 PageID #: 837
`
`6.
`
`Papers Filed Under Seal. In accordance with section G of the Court's Revised
`
`Administrative Procedures Governing Filing and Service by Electronic Means, available at
`
`https://www.ded.uscourts.gov/manualsprocedures, a redacted version of any sealed document
`
`shall be filed electronically within seven (7) days after the filing of the original sealed document.
`
`Courtesy paper copies of sealed documents (see~ 5, above) shall be filed with the Clerk' s Office,
`
`however, courtesy copies of redacted versions of sealed documents shall not be filed, unless
`
`otherwise ordered.
`
`7.
`
`Discovery
`
`(a)
`
`Discovery Cut Off. All discovery in this case shall be initiated so that it will
`
`be completed on or before August 9, 2023. Unless otherwise ordered by the Court, the limitations
`
`on discovery set forth in Local Rule 26.1 shall be strictly observed.
`
`(b)
`
`Document Production. Document production shall be substantially
`
`complete by March 9, 2023.
`
`6z> "".P,-qw\D-
`lOQJ
`Reguests for Admission. A maximum number of (l!l&i11Hf.f:
`
`(c)
`
`,ll>efendaot· 40~ requests for admission are permitted for each side. This limitation does not
`
`include requests for admission directed to the authentication of documents, on which there is no
`
`limit.
`
`(d)
`
`Interrogatories.
`
`1.
`
`A maximum of 25
`
`interrogatories,
`
`including contention
`
`interrogatories, are permitted for each side.
`
`11.
`
`The Court encourages the parties to serve and respond to contention
`
`interrogatories early in the case. In the absence of agreement among the parties, contention
`
`interrogatories, if filed, shall first be addressed by the party with the burden of proof.
`
`3
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 4 of 14 PageID #: 838
`
`(e)
`
`Depositions. Each side is limited to a total of70 hours of taking testimony
`
`by deposition upon oral examination, including Rule 30(b)(l) and Rule 30(b)(6) fact depositions.
`
`Any Rule 30(b)(6) deposition shall count as a single deposition and shall be limited to ten (10)
`
`hours, regardless of the number of individuals designated to testify on behalf of the entity being
`
`deposed. These provisions may be amended by agreement of the parties or upon order of the Court
`
`upon good cause shown.
`
`(f)
`
`Disclosure of Expert Testimony.
`
`I.
`
`Expert Reports. For the party that has the burden of proof on the
`
`subject matter, the initial Federal Rule 26(a)(2) disclosure of expert testimony is due on or before
`
`August 23, 2023. The supplemental disclosure to contradict or rebut evidence on the same subject
`
`matter identified by another party is due on or before September 27, 2023. Reply expert reports
`
`from the party with the initial burden of proof are due on or before November 1, 2023. Along with
`
`the submissions of the expert reports, the parties shall advise of the dates and times of their experts'
`
`availability for deposition. Expert discovery shall be completed by December 6, 2023.
`
`11.
`
`Objections to Expert Testimony. To the extent any objection to
`
`expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow Pharm.,
`
`Inc., 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be made by
`
`motion no later than the deadline for dispositive motions set forth herein, unless otherwise ordered
`
`by the Court.
`
`(g)
`
`Discovery Matters and Disputes Relating to Protective Orders.
`
`Should counsel find they are unable to resolve a discovery matter or a dispute relating to a
`
`protective order, after holding a verbal meet-and-confer and making a reasonable effort to reach
`
`4
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 5 of 14 PageID #: 839
`
`agreement with the opposing party on the matters or dispute, 1 the party seeking relief from the
`
`Court shall file a Motion for Discovery requesting a teleconference to resolve the discovery or
`
`protective order dispute. The Motion shall include the following information:
`
`• A list of no more than three (3) discovery or protective order matters for resolution;
`
`• The date(s) of the verbal meet-and-confer between the parties;
`
`• The format of the meet-and-confer (e.g., in person or by telephone);
`
`• The identity of counsel (including at least one Delaware Counsel and at least one
`
`Lead Counsel per party) who participated in the meet-and-confer; and
`
`• At least three dates on which the parties are jointly available for a teleconference
`
`The Court will thereafter order a discovery teleconference, and the following procedures
`
`shall apply:
`
`1.
`
`11.
`
`111.
`
`IV.
`
`Not less than seventy-two (72) hours prior to the conference,
`excluding weekends and Court holidays, the party seeking relief
`shall file a letter with the Court, not to exceed four ( 4) pages, double(cid:173)
`spaced in no less than 12-point font, outlining the issues in dispute
`and its position on those issues, including proposed solutions.
`
`Not less than forty-eight (48) hours prior to the conference,
`excluding weekends and Court holidays, any party opposing the
`application for relief may file a letter, not to exceed four ( 4) pages,
`double-spaced in no less than 12-point font, outlining that party's
`reason for its opposition and any proposed solutions.
`
`Counsel shall provide a list of the teleconference participants, by
`including the list on a separate page with the letters. This list will
`not count as part of the page limitation for the letter submission.
`
`limited
`should be
`there
`Attachments/Exhibits. Generally,
`attachments or exhibits to the letters. In a protective order dispute,
`only the provisions at issue should be attached. For disputes relating
`to responses to certain discovery requests, only the requests and
`responses in dispute as they exist at the time of the letter submissions
`
`See D. Del. L.R. 7.1.1 (describing the averment of counsel to be filed with nondispositive
`motions).
`
`5
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 6 of 14 PageID #: 840
`
`should be attached. Documentation of the parties' attempts to
`resolve and/or narrow the issues as contained in letters or emails
`shall not be included. However, cases/transcripts cited and relied
`upon in the letter submission may be attached as exhibits.
`
`v.
`
`v1.
`
`To the extent factual issues are disputed or central to the Court's
`analysis,2 non-conclusory, sworn declarations, only to the extent
`necessary to establish the facts, shall be attached as exhibit(s).
`
`Protective Order disputes. For disputes related to the protective
`order, the submissions shall include the party's proposal of the
`content for the disputed portion(s) only of the protective order.
`
`Should the Court find further briefing necessary upon conclusion of the telephonic
`
`conference, the Court will order it. Alternatively, the Court may choose to resolve the dispute prior
`
`to the conference and cancel the conference.
`
`8.
`
`Court Reporter. The parties shall arrange for a court reporter for all hearings and
`
`proceedings including, but not limited to, scheduling conferences, status conferences, discovery
`
`and protective order disputes, hearings, pretrial conference, and trial.
`
`9.
`
`Disclosures. Absent agreement among the parties, and approval of the Court:
`
`(a)
`
`By June 8, 2022, Plaintiff shall identify the accused product(s), including
`
`accused methods and systems, and its damages model, as well as the asserted patent(s) that the
`
`accused product(s) allegedly infringe(s). Plaintiff shall also produce the file history for each
`
`asserted patent.
`
`(b)
`
`By July 27, 2022, Defendant shall produce core technical documents
`
`related to the accused product(s), sufficient to show how the accused product(s) work(s), including
`
`2
`For example, matters addressing attorney-client privilege, work product doctrine, common
`interest doctrine, sufficiency of privilege log and other similar issues often involve factual
`evidence for which affidavits may be required. See RCA v. Data General, C.A. No. 84-270-JJF,
`1986 WL 15693 (D. Del. July 2, 1986); Willemijn Houdstermaatschaapij v. Apollo Computers,
`Inc., 707 F. Supp. 1429 (D. Del. 1989).
`
`6
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 7 of 14 PageID #: 841
`
`but not limited to non-publicly available operation manuals, product literature, schematics, and
`
`specifications. Defendant shall also produce sales figures for the accused product(s).
`
`(c)
`
`By August 24, 2022, Plaintiff shall produce an initial claim chart relating
`
`each known accused product to the asserted claims each such product allegedly infringes.
`
`( d)
`
`By October 5, 2022, Defendant shall produce its initial invalidity
`
`contentions for each asserted claim, as well as the known related invalidating references.
`
`(e)
`
`(f)
`
`By June 28, 2023, Plaintiff shall provide final infringement contentions.
`
`By July 26, 2023, Defendant shall provide final invalidity contentions.
`
`10.
`
`Interim Status Report. On August 2, 2023, counsel shall submit a joint interim
`
`report to the Court on the nature of the matters in issue and the progress of discovery to date.
`
`11.
`
`Status Conference. On August 23, 2023, the Court will hold a telephonic Rule 16
`
`status conference with counsel beginning at ~
`
`a.m. Plaintiffs counsel shall coordinate the
`
`call to chambers. At the time of this conference, counsel shall also be prepared to discuss the
`
`progress, if any, of settlement discussions and shall be prepared to discuss the possibility of setting
`
`up a settlement conference with the Court, counsel and their clients. If all parties agree that there
`
`is nothing to report, nor anything to add to the interim status report or to this Order, they shall
`
`notify the Court in writing before the conference is scheduled to occur, and the conference will be
`
`removed from the Court's calendar.
`
`12.
`
`Technology Tutorials. Although technology tutorials are not required by the Court,
`
`they are appreciated and, if any party chooses to file such a tutorial, it shall be submitted on or
`
`before the date that the Joint Claim Construction Brief is filed.
`
`13.
`
`Claim Construction Issue Identification. On November 9, 2022, the parties shall
`
`exchange a list of those claim term(s)/phrase(s) that they believe need construction and their
`
`7
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 8 of 14 PageID #: 842
`
`proposed claim construction of those term(s)/phrase(s). This document will not be filed with the
`
`Court. Subsequent to exchanging that list, the parties will meet and confer to prepare a Joint Claim
`
`Construction Chart to be filed with the Court on December 7, 2022. The parties Joint Claim
`
`Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue, and
`
`should include each party's proposed construction of the disputed claim language with citation(s)
`
`only to the intrinsic evidence in support of their respective proposed constructions. A copy of the
`
`patent(s) in issue as well as those portions of the intrinsic record relied upon shall be submitted
`
`with this Joint Claim Construction Chart. In this joint submission, the parties shall not provide
`
`argument.
`
`14.
`
`Claim Construction. Plaintiff shall serve, but not file, its opening brief, not to
`
`exceed 20 pages on January 12, 2023. Defendant shall serve, but not file, its answering brief, not
`
`to exceed 30 pages on February 9, 2023. Plaintiff shall serve, but not file, its reply brief, not to
`
`exceed 20 pages, on March 9, 2023. Defendant shall serve, but not file, its sur-reply brief, not to
`
`exceed 10 pages, on March 30, 2023.
`
`No later than April 10, 2023, the parties shall file a Joint Claim Construction Brief, by
`
`copying and pasting their untiled briefs into one brief, with their positions on each claim tem1 in
`
`sequential order, in substantially the form below:
`
`Joint Claim Construction Brief
`
`I.
`
`II.
`
`Agreed-upon Constructions
`
`Disputed Constructions
`
`A.
`
`[Term l]
`
`1.
`
`2.
`
`3.
`
`Plaintiff's Opening Position
`
`Defendant's Answering Position
`
`Plaintiff's Reply Position
`
`8
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 9 of 14 PageID #: 843
`
`4.
`
`Defendant's Sur-Reply Position
`
`B.
`
`[Term 2]
`
`1.
`
`2.
`
`3.
`
`4.
`
`Plaintiffs Opening Position
`
`Defendant's Answering Position
`
`Plaintiffs Reply Position
`
`Defendant's Sur-Reply Position
`
`The above format shall be followed for each claim term in dispute.
`
`The parties need not include any general summaries of the law relating to claim
`
`construction. If there are any materials that would be submitted in an appendix, the parties shall
`
`submit them in a Joint Appendix.
`
`15.
`
`Hearing on Claim Construction. Beginning at _ _ a.m. on __ _, the Court will
`
`hear evidence and argument on claim construction. The parties need not include any general
`
`summaries of the law relating to claim construction in their presentations to the Court. The parties
`
`shall notify the Court, by joint letter submission, no later than the date on which their joint claim
`
`construction brief is filed (i) whether they request leave to present testimony at the hearing; and
`
`(ii) the amount of time they are requesting be allocated to them for the hearing.
`
`Provided that the parties comply with all portions of this Scheduling Order, and any other
`
`orders of the Court, the parties should anticipate that the Court will issue its claim construction
`
`order within sixty days of the conclusion of the claim construction hearing. If the Court is unable
`
`to meet this goal, it will advise the parties no later than sixty days after the conclusion of the claim
`
`construction hearing.
`
`9
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 10 of 14 PageID #: 844
`
`16.
`
`Supplementation. Absent agreement among the parties, and approval of the Court,
`
`no later than June 21, 2023, the parties must finally supplement, inter alia, the identification of
`
`all accused products and of all invalidity references.
`
`17.
`
`Case Dispositive Motions.
`
`(a)
`
`All case dispositive and Daubert motions, an opening brief, and affidavits,
`
`if any, in support of the motion shall be served and filed on or before January 10, 2024. Briefing
`
`will be presented pursuant to the Court's Local Rules,3 except as may be modified during the
`
`scheduling conference. No case dispositive or Daubert motion may be filed at a time before the
`
`date set forth in this paragraph without leave of the Court.
`
`(b)
`
`Detailed Citation Required. Any reference to exhibits in the briefs must
`
`refer to the specific pages of the exhibit proffered in support of a party's argument. If the exhibit
`
`is a deposition, both the page and line numbers must be specified.4
`
`(c)
`
`Page limits. Unless otherwise ordered by the Court, all sides are limited to
`
`a maximum of thirty (30) pages of opening briefs, thirty (30) pages of answering briefs, and
`
`fifteen ( 15) pages of reply briefs relating to any case dispositive and Daubert motions filed by a
`
`side, no matter how many such motions are filed.
`
`18.
`
`Proposed Pretrial Order. The parties shall file with the Court a joint proposed final
`
`pretrial order that includes a table of contents and the matter described in Local Rule 16.3( c) on or
`
`before _ _ _ _ _ . Unless otherwise ordered by the Court, the parties shall comply with the
`
`timeframes set forth in Local Rule 16.3( d)(l )-(3) for the preparation of the joint proposed final
`
`3
`
`See D. Del. L.R. 7 .1.3 ("Form and Contents of Briefs, Memoranda of Points and
`Authorities, and Appendices").
`
`4
`For example, a reference to an exhibit that refers to the entire document will not be
`considered.
`
`10
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 11 of 14 PageID #: 845
`
`pretrial order. The filing of the joint proposed pretrial order shall satisfy the pretrial disclosure
`
`requirement of Rule 26(a)(3).
`
`19. Motions in Limine. Motions in limine shall not be filed separately. All in limine
`
`requests and responses thereto shall be set forth in the proposed pretrial order. Each party shall be
`
`limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine
`
`request and any response shall contain the authorities relied upon; each in limine request may be
`
`supported by a maximum of three (3) pages of argument, may be opposed by a maximum of
`
`three (3) pages of argument, and the side making the in limine request may add a maximum of
`
`one ( 1) additional page in reply in support of its request. If more than one party is supporting or
`
`opposing an in limine request, such support or opposition shall be combined in a single three (3)
`
`page submission (and, if the moving party, a single one (1) page reply), unless otherwise ordered
`
`by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise
`
`permitted by the Court.
`
`20.
`
`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a case is to be tried
`
`to a jury, pursuant to Local Rules 4 7 .1 and 51.1 the parties should file joint proposed (i) voir dire,
`
`(ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms at least
`
`three (3) days, excluding weekends and Court holidays, before the pretrial conference. This
`
`submission shall be accompanied by a courtesy copy containing electronic files of these documents
`
`in Microsoft Word format, which may be submitted by email to the trial judge's staff.
`
`21.
`
`Pretrial Conference. On _ _ _ __, the Court will hold a pretrial conference in
`
`Courtroom 2B with counsel beginning at _ _ _
`
`22.
`
`Trial. This matter is scheduled for a 5-7 day jury trial beginning at 9:30 a.m. on
`
`- - -- with the remaining trial days beginning at 9:00 a.m. Until the case is submitted to the
`
`11
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 12 of 14 PageID #: 846
`
`jury for deliberations, the jury will be excused each day at 4:30 p.m. The trial will be timed, and
`
`each side will be allocated a total number of hours in which to present their case.
`
`23.
`
`Judgment on Verdict and Post-Trial Status Report. Within seven days after a jury
`
`returns a verdict in any portion of a jury trial, the parties shall jointly submit a form of order to
`
`enter judgment on the verdict. At the same time, the parties shall submit a joint status report,
`
`indicating among other things how the case should proceed and listing any post-trial motions each
`
`party intends to file.
`
`24.
`
`Post-Trial Motions. Unless otherwise ordered by the Court, all sides are limited to
`
`a maximum of twenty (20) pages of opening briefs, twenty (20) pages of answering briefs, and ten
`
`(10) pages of reply briefs relating to any post-trial motions filed by one side, no matter how many
`
`such motions are filed.
`
`12
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 13 of 14 PageID #: 847
`
`Chart of All Relevant Deadlines
`
`Initial Disclosures & review ESI Default
`Order
`
`14 days after date of Scheduling Order
`
`Default Standard Paragraph 3 Disclosures
`
`30 days after date of Scheduling Order
`
`Application for Protective Order
`
`30 days after date of Scheduling Order
`
`Plaintiffs Identification of Accused Products Wednesday, June 8, 2022
`& Damages Model
`
`Defendant's Core Technical Document
`Production
`
`Wednesday, July 27, 2022
`
`Plaintiffs Initial Claim Chart
`
`Wednesday, August24, 2022
`
`Defendant's Invalidity Contentions
`
`Wednesday, October 5, 2022
`
`Claim Construction Term Exchange
`
`Wednesday, November 9, 2022
`
`Joint Claim Construction Chart (at least 2
`weeks prior to opening Claim Construction
`brief)
`
`Wednesday, December 7, 2022
`
`Plaintiffs Opening Claim Construction Brie
`
`Thursday, January 12, 2023
`
`Defendant's Answering Claim Construction
`Brief
`
`Thursday, February 9, 2023
`
`Plaintiffs Reply Claim Construction Brief
`
`Thursday, March 9, 2023
`
`Substantial Completion of Document
`Production
`
`Thursday, March 9, 2023
`
`Joinder of Parties and Amended Pleadings
`
`Thursday, March 30, 2023
`
`Defendant's Sur-Reply Claim Construction
`Brief
`
`Thursday, March 30, 2023
`
`Joint Claim Construction Brief & any
`Technology Tutorials
`
`Monday, April 10, 2023
`
`Markman Hearing
`
`TBD
`
`

`

`Case 1:21-cv-01823-GBW Document 25 Filed 05/06/22 Page 14 of 14 PageID #: 848
`
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`. ~;,: ..... , .. <}b··<
`·~- ,;~:;::,_;:
`~ .. ,,,·
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`·f
`
`,
`
`Supplemental Identification of Accused
`Products/Invalidity References
`
`Wednesday, June 21, 2023
`
`Plaintiffs Final Infringement Contentions
`
`Wednesday, June 28, 2023
`
`Defendant's Final Invalidity Contentions
`
`Wednesday, July 26, 2023
`
`Interim Status Report
`
`Fact Discovery Close
`
`Status Conference (after interim status
`report)
`
`Opening Expert Reports
`
`Rebuttal Expert Reports
`
`Reply Expert Reports
`
`Expert Discovery Close
`
`Wednesday, August 2, 2023
`
`Wednesday, August 9, 2023
`
`Wednesday, August 23, 2023
`
`Wednesday, August 23, 2023
`
`Wednesday, September 27, 2023
`
`Wednesday, November 1, 2023
`
`Wednesday, December 6, 2023
`
`Dispositive Motions & Opening Briefs
`
`Wednesday, January 10, 2024
`
`Dispositive Answering Briefs
`
`Wednesday, January 24, 2024
`
`Dispositive Reply Briefs
`
`Wednesday, January 31, 2024
`
`Dispositive/Daubert Motions Hearing
`
`Final Pre-Trial Order (at least 7 days prior to
`pretrial conference)
`
`Jury Instructions, Voir Dire, Special Verdict
`Forms ( at least 3 days before pretrial
`conference)
`
`Pre-Trial Conference
`
`Trial
`
`TBD
`
`TBD
`
`TBD
`
`TBD
`
`TBD
`
`2
`
`