Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 1 of 22 PageID #: 2099
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`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 1 of 22 PagelD #: 2099
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`EXHIBIT |
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`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 1 of 22 PagelD #: 2099
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`EXHIBIT |
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`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 2 of 22 PageID #: 2100
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`
`
`
`NOKIA TECHNOLOGIES OY,
`
`
`Plaintiff / Counterclaim Defendant,
`
`
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` HP, Inc.,
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`Defendant / Counterclaim Plaintiff
`
`
`v.
`
`
`
`
`C.A. No. 23-cv-1237-GBW
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`
`
`
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`[PROPOSED) SCHEDULING ORDER [PATENT, NON-ANDA)
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`
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`This
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` day of
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`
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` 20
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`, the Court having conducted an
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`initial Rule 16(b) scheduling conference pursuant to Local Rule 16.l(b), and the
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`parties having determined after discussion that the matter cannot be resolved at
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`this juncture by settlement, voluntary mediation, or binding arbitration;
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`IT IS HEREBY ORDERED that:
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`
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`1.
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`Rule 26(a)(1) Initial Disclosures and E-Discovery Default Standard.
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`Unless otherwise agreed to by the parties, the parties shall make their
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`initial disclosures pursuant to Federal Rule of Civil Procedure 26(a)(l) within
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`five (5) days of the date the Court enters this Order. If they have not already
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`done so, the parties are to review the Court's Default Standard for Discovery,
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`Including Discovery of Electronically Stored Information (''ESI"), which is
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`posted at http://www.ded.uscourts.gov (see Other Resources, Default Standard
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`1
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`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 3 of 22 PageID #: 2101
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`for Discovery) and is incorporated herein by reference.
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`2.
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`Joinder of Other Parties and Amendment of Pleadings. All motions
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`to join other parties, and to amend or supplement the pleadings, shall be filed on
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`or before December 2, 2024. Unless otherwise ordered by the Court, any
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`motion to join a party or motion to amend the pleadings shall be made pursuant
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`to the procedures set forth in Paragraphs 4(g) and 5.
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`3.
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`Disclosures. Absent agreement among the parties, and approval of
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`the Court:
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`(a) By July 26, 2024, Plaintiff shall identify the accused
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`product(s), including accused methods and systems, and its damages model, as
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`well as the asserted patent(s) that the accused product(s) allegedly infringe(s).
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`Plaintiff shall also produce the file history for each asserted patent.
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`(b) By September 6, 2024, Defendant shall produce core
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`technical documents related to the accused product(s), sufficient to show how
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`the accused product(s) work(s), including but not limited to non-publicly
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`available operation manuals, product literature, schematics, and specifications.
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`Defendant shall also produce sales figures for the accused product(s).
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`(c) By October 15, 2024, Plaintiff shall produce an initial claim
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`chart relating each known accused product to the asserted claims each such
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`product allegedly infringes.
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`2
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`(d) By December 2, 2024, Defendant shall produce its initial
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`invalidity contentions for each asserted claim, as well as the known related
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`invalidating references.
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`(e) By June 5, 2025, Plaintiff shall provide final infringement
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`contentions.
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`contentions.
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`(f) By June 26, 2025, Defendant shall provide final invalidity
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`4.
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` Discovery. Unless otherwise ordered by the Court or agreed to by
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`parties, the limitations on discovery set forth in the Federal Rules of Civil
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`Procedure shall be strictly observed.
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`(a)
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`Fact Discovery: Cut Off. All fact discovery in this case shall
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`be initiated so that it will be completed on or before July 25, 2025.
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`(b) Document Production. Document production shall be
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`substantially complete by April 25, 2025.
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`(c) Requests for Admission. A maximum of 50 requests for
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`admission are permitted for each side.
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`(d)
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`Interrogatories.
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`i.
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`A maximum of 30 interrogatories, including
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`contention interrogatories, are permitted for each side.
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`ii.
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`The Court encourages the parties to serve and respond
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`3
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`to contention interrogatories early in the case. In the absence of agreement
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`among the parties, contention interrogatories, if filed, shall first be addressed by
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`the party with the burden of proof. The adequacy of all interrogatory answers
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`shall be judged by the level of detail each party provides (i.e., the more detail a
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`party provides, the more detail a party shall receive).
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`(e) Depositions.
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`i.
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`Limitation on Hours for Deposition Discovery. Each
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`side is limited to a total of 70 hours of taking testimony of fact witnesses by
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`deposition upon oral examination.
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`ii.
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`Location of Depositions. Any party or representative
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`(officer, director, or managing agent) of a party filing a civil action in this
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`district court must ordinarily be required, upon request, to submit to a
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`deposition at a place designated within this district. Exceptions to this general
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`rule may be made by order of the Court. A defendant who becomes a
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`counterclaimant, cross-claimant, or third-party plaintiff shall be considered as
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`having filed an action in this Court for the purpose of this provision.
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`(f) Disclosure of Expert Testimony.
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`i.
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`Expert Reports. For the party who has the initial
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`burden of proof on the subject matter, the initial Federal Rule of Civil
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`Procedure 26(a)(2) disclosure of expert testimony is due on or before August
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`4
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`26, 2025. The supplemental disclosure to contradict or rebut evidence on the
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`same matter identified by another party is due on or before September 26, 2025.
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`Reply expert reports from the party with the initial burden of proof are due on
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`or before October 15, 2025. No other expert reports will be permitted without
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`either the consent of all parties or leave of the Court. Along with the
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`submissions of the expert reports, the parties shall advise of the dates and times
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`of their experts' availability for deposition.
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`ii.
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`Objections to Expert Testimony. To the extent any
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`objection to expert testimony is made pursuant to the principles announced in
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`Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), as
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`incorporated in Federal Rule of Evidence 702, it shall be made by motion no
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`later than the deadline for dispositive motions set forth herein, unless otherwise
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`ordered by the Court. Briefing on such motions is subject to the page limits set
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`out in connection with briefing of case dispositive motions.
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`iii.
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`Expert Discovery Cut-Off. All expert discovery in this
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`case shall be initiated so that it will be completed on or before November 14,
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`2025.
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`(g) Discovery Matters and Disputes Relating to Protective Orders.
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`i.
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`Any discovery motion filed without first complying
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`with the following procedures will be denied without prejudice to renew
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`pursuant to these procedures.
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`ii.
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`Should counsel find, after good faith efforts -
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`including verbal communications among Delaware and Lead Counsel for all
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`parties to the dispute - that they are unable to resolve a discovery matter or a
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`dispute relating to a protective order, the parties involved in the discovery
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`matter or protective order dispute shall submit a joint letter in substantially the
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`following form:
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`
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`Dear Judge Williams:
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`The parties in the above-referenced
`matter write to request the scheduling of a
`discovery teleconference.
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`The following attorneys, including at
`least one Delaware Counsel and at least one
`Lead Counsel per party, participated in a verbal
`meet(cid:173) and-confer (in person and/or by
`telephone) on the following date(s):
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`Delaware Counsel:
`Lead Counsel:
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`
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`The disputes requiring judicial attention
`are listed below:
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`[provide here a non-argumentative list of
`disputes requiring judicial attention]
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`On a date to be set by separate order, generally not
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`iii.
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`less than forty-eight (48) hours prior to the conference, the party seeking relief
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`shall file with the Court a letter, not to exceed three (3) pages, outlining the
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`issues in dispute and its position on those issues. On a date to be set by separate
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`order, but generally not less than twenty-four (24) hours prior to the conference,
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`any party opposing the application for relief may file a letter, not to exceed
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`three (3) pages, outlining that party's reasons for its opposition.
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`iv.
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`Each party shall submit two (2) courtesy copies of its
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`discovery letter and any attachments.
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`v.
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`Should the Court find further briefing necessary upon
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`conclusion of the telephone conference, the Court will order it. Alternatively,
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`the Court may choose to resolve the dispute prior to the telephone conference
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`and will, in that event, cancel the conference.
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`5. Motions to Amend.
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`(a) Any motion to amend (including a motion for leave to
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`amend) a pleading shall NOT be accompanied by an opening brief but shall,
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`instead, be accompanied by a letter, not to exceed three (3) pages, describing
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`the basis for the requested relief, and shall attach the proposed amended
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`pleading as well as a "blackline" comparison to the prior pleading.
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`(b) Within seven (7) days after the filing of a motion in
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`compliance with this Order, any party opposing such a motion shall file a
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`responsive letter, not to exceed five (5) pages.
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`(c) Within three (3) days thereafter, the moving party may file a
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`reply letter, not to exceed two (2) pages, and, by this same date, the parties shall
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`file a letter requesting a teleconference to address the motion to amend.
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`6. Motions to Strike.
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`(a) Any motion to strike any pleading or other document shall
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`NOT be accompanied by an opening brief but shall, instead, be accompanied by
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`a letter, not to exceed three (3) pages, describing the basis for the requested
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`relief, and shall attach the document to be stricken.
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`(b) Within seven (7) days after the filing of a motion in
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`compliance with this Order, any party opposing such a motion shall file a
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`responsive letter, not to exceed five (5) pages.
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`(c) Within three (3) days thereafter, the moving party may file a
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`reply letter, not to exceed two (2) pages, and, by this same date, the parties shall
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`file a letter requesting a teleconference to address the motion to strike.
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`7.
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`Technology Tutorials. Unless otherwise ordered by the Court, the
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`parties jointly shall provide the Court, no later than the date on which the Joint
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`Claim Construction Chart is due, a tutorial on the technology at issue. In that
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`regard, the parties shall jointly submit to the Court an electronic tutorial of not
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`more than thirty (30) minutes. The tutorial should focus on the technology in
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`issue and educate the Court about the same and should not be used for
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`argument. As to the format selected, the parties should confirm the Court's
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`technical abilities to access the information contained in the tutorial ("mpeg",
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`"quicktime", etc.). The parties may choose to file their tutorial under seal,
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`subject to any protective order in effect.
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`8.
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`Claim Construction Issue Identification. On or before December
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`16, 2024, the parties shall exchange a list of those claim term(s)/phrase(s) that
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`they believe need construction and their proposed claim construction of those
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`term(s)/phrase(s). On or before December 23, 2024, the parties shall respond to
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`and provide their proposed construction for any term(s)/phrase(s) presented by
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`the other side for which the party did not initially provide a construction. These
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`documents will not be filed with the Court. Subsequent to exchanging that list,
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`the parties will meet and confer to prepare a Joint Claim Construction Chart to
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`be filed no later than January 7, 2025. The Joint Claim Construction Chart, in
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`Word format, shall be e-mailed simultaneously with filing to
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`gbw_civil@ded.uscourts.gov. The parties' Joint Claim Construction Chart
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`should identify for the Court the term(s)/phrase(s) of the claim(s) in issue, and
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`should include each party's proposed construction of the disputed claim
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`language with citation(s) only to the intrinsic evidence in support of their
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`respective proposed constructions. A copy of the patent(s) in issue as well as
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`those portions of the intrinsic record relied upon shall be submitted with this
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`Joint Claim Construction Chart. In this joint submission, the parties shall not
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`provide argument.
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`9.
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`Claim Construction Briefing. Plaintiff shall serve, but not file, its
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`opening brief, not to exceed 5,000 words, on January 17, 2025. Defendant shall
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`serve, but not file, its answering brief not to exceed 7,500 words, on February
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`22, 2025. Plaintiff shall serve, but not file, its reply brief, not to exceed 5,000
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`words, on March 7, 2025. Defendant shall serve, but not file its sur-reply brief,
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`not to exceed 2,500 words, on March 21, 2025. No later than March 28, 2025
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`the parties shall file a Joint Claim Construction Brief. The parties shall copy and
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`paste their untiled briefs into one brief, with their positions on each claim term
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`in sequential order, in substantially the form below.
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`JOINT CLAIM CONSTRUCTION BRIEF
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`1.
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`2.
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`Agreed-Upon Constructions
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`Disputed Constructions
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`[TERM 1]
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`(a) Plaintiffs Opening Position
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`(b) Defendant's Answering Position
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`(c) Plaintiffs Reply Position
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`(d) Defendant's Sur-Reply Position
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`[TERM 2]
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`1.
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`Plaintiffs Opening Position
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`2. Defendant's Answering Position
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`3.
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`Plaintiffs Reply Position
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`4. Defendant's Sur-Reply Position
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`If there are any materials that would be submitted in an index, the parties
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`shall submit them in a Joint Appendix.
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`10. Hearing on Claim Construction. Beginning at 9:30 a.m. on April
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`21, 2025, the Court will hear argument on claim construction. The parties shall
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`notify the Court, by joint letter submission, no later than the date on which their
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`answering claim construction briefs are due: (i) whether they request leave to
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`present testimony at the hearing; and (ii) the amount of time they are requesting
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`be allocated to them for the hearing.
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`Provided that the parties comply with all portions of this Scheduling
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`Order, and any other orders of the Court, the parties should anticipate that the
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`Court will issue its claim construction order within sixty (60) days of the
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`conclusion of the claim construction hearing. If the Court is unable to meet this
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`goal, it will advise the parties no later than sixty (60) days after the conclusion
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`of the claim construction hearing.
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`11.
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`Interim Status Report. On June 18, 2025, counsel shall submit a
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`joint letter to the Court with an interim report of the matters in issue and the
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`progress of discovery to date. Thereafter, if the Court deems it necessary, it will
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`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 13 of 22 PageID #: 2111
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`schedule a status conference.
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`12. Supplementation. Absent agreement among the parties, and
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`approval of the Court,
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`(a)
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`no later than June 5, 2025 the patentee must finally
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`supplement the identification of all accused products and serve final
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`infringement contentions; and
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`(b)
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`no later than June 26, 2025 the accused infringers must
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`finally supplement the identification of all invalidity references and serve final
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`invalidity contentions.
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`13. Case Dispositive Motions.
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`(a) All case dispositive motions, an opening brief, and
`
`affidavits, if any, in support of the motion shall be served and filed on or before
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`December 15, 2025. Briefing will be presented pursuant to the Court's Local
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`Rules. No case dispositive motion under Rule 56 may be filed more than ten
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`(10) days before the above date without leave of the Court.
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`(b) Concise Statement of Facts Requirement. Any motion for
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`summary judgment shall be accompanied by a separate concise statement, not
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`to exceed six (6) pages, which details each material fact which the moving party
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`contends is essential for the Court's resolution of the summary judgment motion
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`(not the entire case) and as to which the moving party contends there is no
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`12
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`genuine issue to be tried. Each fact shall be set forth in a separate numbered
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`paragraph and shall be supported by specific citation(s) to the record.
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`Any party opposing the motion shall include with its opposing
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`papers a response to the moving party's concise statement, not to exceed six (6)
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`pages, which admits or disputes the facts set forth in the moving party's concise
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`statement on a paragraph-by-paragraph basis. To the extent a fact is disputed,
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`the basis of the dispute shall be supported by specific citation(s) to the record.
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`Failure to respond to a fact presented in the moving party's concise statement of
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`facts shall indicate that fact is not in dispute for purposes of summary judgment.
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`The party opposing the motion may also include with its opposing papers a
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`separate concise statement, not to exceed four (4) pages, which sets forth
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`material facts as to which the opposing party contends there is a genuine issue
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`to be tried. Each fact asserted by the opposing party shall also be set forth in a
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`separate numbered paragraph and shall be supported by specific citation(s) to
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`the record.
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`The moving party shall include with its reply papers a response to
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`the opposing party's concise statement of facts, not to exceed four (4) pages, on
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`a paragraph-by-paragraph basis. Failure to respond to a fact presented in the
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`opposing party's concise statement of facts shall indicate that fact remains in
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`dispute for purposes of summary judgment.
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`13
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`(c)
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`Page limits combined with Daubert motion page limits. Each
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`party is permitted to file as many case dispositive motions as desired provided,
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`however, that each SIDE will be limited to a combined total of 40 pages for all
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`opening briefs, a combined total of 40 pages for all answering briefs, and a
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`combined total of 20 pages for all reply briefs regardless of the number of case
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`dispositive motions that are filed. In the event that a party files, in addition to a
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`case dispositive motion, a Daubert motion to exclude or preclude all or any
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`portion of an expert's testimony, the total amount of pages permitted for all case
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`dispositive and Daubert motions shall be increased to 50 pages for all opening
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`briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs for
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`each SIDE.1
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`(d) Ranking of Summary Judgment Motions. Any party that
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`files more than one summary judgment motion shall number each motion to
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`indicate the order in which the party wishes the Court to review its pending
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`motions. The first motion the party wishes the Court to consider shall be
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`designated #1, the second motion shall be designated #2, and so on. The Court
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`1 The parties must work together to ensure that the Court receives no more than
`a total of 250 pages (i.e., 50 + 50 + 25 regarding one side's motions, and 50 +
`50 + 25 regarding the other side's motions) of briefing on all case dispositive
`motions and Daubert motions that are covered by this scheduling order and any
`other scheduling order entered in any related case that is proceeding on a
`consolidated or coordinated pretrial schedule.
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`will review the party's summary judgment motions in the order designated by
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`the party. If the Court decides to deny a motion filed by the party, barring
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`exceptional reasons determined sua sponte by the Court, the Court will not
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`review any lower ranked summary judgment motions filed by the party.
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`14. Applications by Motion. Except as otherwise specified herein, any
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`application to the Court shall be by written motion. Any non-dispositive motion
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`should contain the statement required by Local Rule 7.1.1.
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`15. Application to Court for Protective Order. Should counsel find it
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`will be necessary to apply to the Court for a protective order specifying terms
`
`and conditions for the disclosure of confidential information, counsel should
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`confer and attempt to reach an agreement on a proposed form of order and
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`submit it to the Court within ten (10) days from the date the Court enters this
`
`Order. Should counsel be unable to reach an agreement on a proposed form of
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`order, counsel must follow the provisions of Paragraph 4(g) above.
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`Any proposed protective order must include the following paragraph:
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`
`
`
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`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
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`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.
`
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`16. Papers Filed Under Seal. In accordance with section G of the
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`Revised Administrative Procedures Governing Filing and Service by Electronic
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`Means, a redacted version of any sealed document shall be filed electronically
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`within seven (7) days of the filing of the sealed document.
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`17. Courtesy Copies. The parties shall provide to the Court two (2)
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`courtesy copies of filings (i.e., briefs, appendices, exhibits, declarations,
`
`affidavits etc.). Courtesy copies of appendices and exhibits should include hard
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`tabs. This provision also applies to papers filed under seal.
`
`18. Motions in Limine. Motions in limine shall not be separately filed.
`
`All in limine requests and responses thereto shall be set forth in the proposed
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`pretrial order. Each SIDE shall be limited to three (3) in limine requests, unless
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`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
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`a maximum of one (1) additional page in reply in support of its request. If more
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`than one party is supporting or opposing an in limine request, such support or
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`opposition shall be combined in a single three (3) page submission (and, if the
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`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
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`otherwise permitted by the Court.
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`19. Pretrial Conference. On June 5, 2026, the Court will hold a pretrial
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`conference in Court with counsel beginning at 9:30 a.m. Unless otherwise
`
`ordered by the Court, the parties should assume that filing the pretrial order
`
`satisfies the pretrial disclosure requirement of Federal Rule of Civil Procedure
`
`26(a)(3). The parties shall file with the Court the joint proposed final pretrial
`
`order in compliance with Local Rule 16.3(c) and the Court's Preferences and
`
`Procedures for Civil Cases not later than seven (7) days before the pretrial
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`conference. 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
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`the joint proposed final pretrial order.
`
`The parties shall provide the Court two (2) courtesy copies of the joint
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`proposed final pretrial order and all attachments. The proposed final pretrial
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`order shall contain a table of contents and the paragraphs shall be numbered.
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`20.
`
`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a
`
`case is to be tried to a jury, pursuant to Local Rules 47.l(a)(2) and 51.1 the
`
`
`
`17
`
`
`
`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 19 of 22 PageID #: 2117
`
`parties should file (i) proposed voir dire, (ii) preliminary jury instructions, (iii)
`
`final jury instructions, and (iv) special verdict forms seven (7) business days
`
`before the final 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 e-mail to
`
`gbw_civil@ded.uscourts.gov.
`
`21. Trial. This matter is scheduled for a five day jury trial beginning at
`
`9:30 a.m. on June 15, 2026 with the subsequent trial days beginning at 9:30
`
`a.m. Until the case is submitted to the jury for deliberations, the jury will be
`
`excused each day at 5:30 p.m. The trial will be timed, as counsel will be
`
`allocated a total number of hours in which to present their respective cases.
`
`22.
`
`Judgment on Verdict and Post-Trial Status Report. Within seven
`
`(7) 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.
`
`23. Post-Trial Motions. Unless otherwise ordered by the Court, all
`
`SIDES are limited to a maximum of 20 pages of opening briefs, 20 pages of
`
`answering briefs, and 10 pages of reply briefs relating to any post-trial motions
`
`
`
`18
`
`
`
`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 20 of 22 PageID #: 2118
`
`filed by that side, no matter how many such motions are filed.
`
`24. ADR Process. This matter is referred to a magistrate judge to
`
`explore the possibility of alternative dispute resolution.
`
`
`
`
`
`
`
`The Honorable Gregory B. Williams
`United States District Judge
`
`
`
`
`
`19
`
`
`
`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 21 of 22 PageID #: 2119
`
`Counsel Shall Provide a Chart of All Relevant Deadlines
`
`EVENT
`
`
`
`Plaintiff shall identify asserted patent(s), the accused
`product(s), and damages model. Plaintiff shall also
`produce the file history for each asserted patent
`
`DEADLINE
`
`July 26, 2024
`
`Defendant shall produce core technical documents and
`sales figures for the accused product(s).
`
`September 6, 2024
`
`Initial Infringement Contentions
`
`October 15, 2024
`
`Joinder of Other Parties and Amendment of Pleadings
`
`December 2, 2024
`
`Initial Invalidity Contentions
`
`The parties shall exchange a list of those claim
`term(s)/phrase(s) that they believe need construction
`and their proposed claim construction of those
`term(s)/phrase(s).
`
`The parties shall respond to and provide their proposed
`construction for any term(s)/phrase(s) presented by the
`other side for which the party did not initially provide a
`construction.
`
`Joint Claim Construction Chart
`
`Opening Claim Construction Brief
`
`December 2, 2024
`
`December 16, 2024,
`
`December 23, 2024
`
`
`
`January 7, 2025
`
`January 17, 2025
`
`
`
`Answering Claim Construction Brief
`
`February 22, 2025
`
`Reply Claim Construction Brief
`
`Sur-Reply Claim Construction Brief
`
`Joint Claim Construction Brief and Technology
`Tutorials
`
`March 7, 2025
`
`March 21, 2025
`
`March 28, 2025
`
`Claim Construction Hearing
`
`April 21, 2025
`
`Substantial Completion of Document Production
`
`April 28, 2025
`
`Final Infringement Contentions
`
`Interim Status Report
`
`Final Invalidity Contentions
`
`Close of Fact Discovery
`
`Opening Expert Reports
`
`Rebuttal Expert Reports
`
`
`
`June 5, 2025
`
`June 18, 2025
`
`June 26, 2025
`
`July 25, 2025
`
`August 26, 2025
`
`September 26, 2025
`
`
`
`Case 1:23-cv-01237-GBW Document 32-1 Filed 06/13/24 Page 22 of 22 PageID #: 2120
`
`Reply Expert Reports
`
`Expert Discovery Cut-Off
`
`October 15, 2025
`
`November 14, 2025
`
`Case Dispositive Motions and Daubert Motions
`
`December 15, 2025
`
`Responses to Case Dispositive Motions and Daubert
`Motions
`
`Replies in Support of Case Dispositive Motions and
`Daubert Motions
`
`Final Pretrial Conference
`
`Jury Selection/Trial
`
`January 21, 2026
`
`February 3, 2026
`
`
`
`June 5, 2026
`
`June 15, 2026
`
`
`
`
`
`
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