`Case 1:14-cv-02396-PGG-MHD Document 174 Filed 09/12/19 Page 1 of 3
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`NETWORK-I TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`V.
`
`14 Civ. 2396 (PGG)
`
`14 Civ. 9558 (PGG)
`
`GOOGLE LLC and YOUTUBE, LLC,
`
`Defendants.
`
`JOINT STIPULATION TO MODIFY THE DEADLINE FOR
`COMPLETION OF DEPOSITIONS OF FACT WITNESSES
`
`PlaintiffNetwork-1 Technologies, Inc. and Defendants Google LLC and YouTube, LLC,
`
`through their undersigned counsel, hereby stipulate, subject to approval by this Court, to modify
`
`the deadline for the completion of depositions of fact witnesses set forth in the January 17, 2019
`
`Joint Proposed Civil Case Management Plan and Scheduling Order ("Scheduling Order," Dkt.
`
`No. 137-1 ~ 8.e). 1
`
`WHEREAS, Plaintiff Network-I and Defendants have completed the interim discovery
`
`deadlines set forth in sub-paragraphs a, b, c, d, and f of paragraph 8 of the Scheduling Order;
`
`WHEREAS, Network-I and Defendants agree to complete both party and non-party
`
`written discovery by September 30, 2019 (the date set forth in paragraph 7 of the Scheduling
`
`Order for the completion of fact discovery);
`
`WHEREAS, because there are at least about ten fact depositions yet to be completed,
`
`most of which will require cross-country or international travel as well as the coordination of
`
`1 Citations to the docket refer to docket entries in Case No. 14 Civ. 2396 (PGG).
`
`
`
`Case 1:14-cv-09558-PGG Document 115 Filed 09/18/19 Page 2 of 3
`Case 1:14-cv-02396-PGG-MHD Document 174 Filed 09/12/19 Page 2 of 3
`
`counsel's and witnesses' schedules, Network-I and Defendants agree that it would be
`
`beneficial to extend the deadline to complete depositions of fact witnesses from September 30,
`
`2019 (see Scheduling Order paragraph 8.e) to November 1, 2019;
`
`WHEREAS, in accordance with paragraph 13 of the Scheduling Order, counsel for
`
`Network-I and Defendants will meet face-to-face for at least one hour to discuss settlement no
`
`later than November 15, 2019;
`
`WHEREAS, no other deadlines will be affected, including the expert discovery and
`
`dispositive motion deadlines set forth in paragraphs 12 and 14 of the Scheduling Order,
`
`respectively;
`
`NOW THEREFORE, the parties hereby stipulate and agree as follows:
`
`1.
`
`Network-I and Defendants will complete both party and non-party written
`
`discovery by September 30, 2019;
`
`2.
`
`Network-I and Defendants will complete depositions of fact witnesses by
`
`November 1, 2019; and
`
`3.
`
`Counsel for Network-I and Defendants will meet face-to-face for at least one
`
`hour to discuss settlement no later than November 15, 2019.
`
`2
`
`
`
`Case 1:14-cv-09558-PGG Document 115 Filed 09/18/19 Page 3 of 3
`Case 1:14-cv-02396-PGG-MHD Document 174 Filed 09/12/19 Page 3 of 3
`
`SO STIPULATED.
`
`Dated: September 12, 2019
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`WILLIAMS & CONNOLLY LLP
`
`BY: Isl Amy E. Havden
`
`BY: Isl Samuel Bryant Davidoff
`
`Marc A. Fenster (pro hac vice)
`Brian D. Ledahl (pro hac vice)
`Adam S. Hoffman (pro hac vice)
`Paul A. Kroeger (pro hac vice)
`Amy E. Hayden (pro hac vice)
`12424 Wilshire Blvd. 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
`mfenster@raklaw.com
`bledahl@raklaw.com
`ahoffman@raklaw.com
`pkroeger@raklaw.com
`ahayden@raklaw.com
`
`Charles R. Macedo
`AMSTER, ROTHSTEIN &
`EBENSTEIN LLP
`90 Park A venue
`New York, NY 10016
`Phone: (212) 336-8074
`Fax: (212) 336-8001
`cmacedo@arelaw.com
`
`Attorneys for Network-I
`Technologies, Inc.
`
`Samuel Bryant Davidoff
`650 Fifth Avenue, Suite 1500
`New York, NY 10022
`212-688-9224
`sdavidoff@wc.com
`
`Bruce R. Genderson (pro hac vice)
`Kevin Hardy (pro hac vice)
`Andrew V. Trask
`725 Twelfth St., N.W.
`Washington, DC 20005
`Phone: (202) 434-5000
`Fax: (202) 434-5029
`bgenderson@wc.com
`khardy@wc.com
`atrask@wc.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`SO ORDERED.
`Date: ~ .. (~ '?ot°f
`
`f<¼{i-4~
`
`Paul G. Garde he
`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
