`Case 1:14-cv-09558-PGG-SN Document 138 Filed 11/14/19 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 EXPERT DISCOVERY DEADLINES
`
`Plaintiff Network-I Technologies, Inc. and Defendants Google LLC and YouTube, LLC,
`
`through their undersigned counsel, hereby stipulate, subject to approval by this Court, to modify
`
`the expert discovery deadlines set forth in the October 21, 2019 Joint Proposed Civil Case
`
`Management Plan and Scheduling Order (Dkt. No. 189) 1 in order to permit sufficient time for
`
`the parties to finish source code review and to address issues remaining following the close of
`
`fact discovery.
`
`WHEREAS, opening expert reports are currently due for service on November 25,
`
`2019;
`
`WHEREAS, rebuttal expert reports are currently due for service on January 17, 2020;
`
`WHEREAS, the close of expert discovery is currently February 7, 2020;
`
`WHEREAS, letters seeking leave to file dispositive motions are currently due on
`
`February 21, 2020, with opposition letters due February 28, 2020;
`
`1 Citations to the docket refer to docket entries in Case No. 14 Civ. 2396 (PGG).
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 199 Filed 11/13/19 Page 2 of 3
`Case 1:14-cv-09558-PGG-SN Document 138 Filed 11/14/19 Page 2 of 3
`
`WHEREAS, the parties still need to complete the fact discovery-related tasks outlined
`
`above, necessitating additional time before expert discovery begins;
`
`NOW THEREFORE, the parties hereby stipulate and agree as follows:
`
`1.
`
`2.
`
`3.
`
`The parties may serve opening expert reports by December 20, 2019;
`
`The parties may serve rebuttal expert reports by February 14, 2020;
`
`Any application for leave to serve a reply expert report must be filed by
`
`February 21, 2020;
`
`4.
`
`The parties must complete expert discovery, including depositions of experts,
`
`by March 13, 2020;
`
`5.
`
`Any letter seeking leave to file dispositive motions must be filed by March 27,
`
`2020, and any opposition letters must be filed by April 3, 2020.
`
`2
`
`
`
`Case 114-cv-02396-PGG-SN Document 199 Filed 11/13/19 Page 3 of 3
`Case 1:14-cv-09558-PGG-SN Document 138 Filed 11/14/19 Page 3 of 3
`
`SO STIPULATED.
`
`Dated: November 13, 2019
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`WILLIAMS & CONNOLLY LLP
`
`BY: Isl Brian D. Ledahl
`
`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)
`Arny E. Hayden (pro hac vice)
`Jacob R. Buczko (pro hac vice)
`12424 Wilshire BIvd. 12 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 A venue, 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
`Graham W. Safty (pro hac vice)
`Sumeet P. Dang (pro hac vice)
`725 Twelfth St. NW
`Washington, DC 20005
`Phone: (202) 434-5000
`Fax:(202)434-5029
`bgenderson@wc.com
`khardy@wc.com
`atrask@wc.com
`gsafty@wc.com
`sdang@wc.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`SO ORDERED.
`
`Dae hoot3, 2Z,/-f
`
`Paul G. Gardephe
`United States District Judge
`
`3
`
`
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