`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`
`
`
`
`NETWORK-1 TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC and YOUTUBE, LLC,
`
`Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`14 Civ. 2396 (PGG-SN)
`
`14 Civ. 9558 (PGG-SN)
`
`
`
`
`
`
`JOINT STIPULATION TO MODIFY THE DEADLINE FOR
`THE CLOSE OF EXPERT DISCOVERY
`
`Plaintiff Network-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 deadlines set forth in the October 21, 2019 Joint Proposed Civil Case Management Plan and
`
`Scheduling Order (Dkt. No. 189)1 and the March 27, 2020 Joint Stipulation to Modify the
`
`Deadline for the Close of Expert Discovery (Dkt. No. 211).
`
`WHEREAS, the close of expert discovery is currently June 30, 2020;
`
`WHEREAS, numerous states and municipalities are under “stay at home” orders,
`
`including those in which at least some counsel of record and expert witnesses reside;
`
`WHEREAS, as a result of the aforementioned situation, the parties have recently
`
`agreed to conduct expert depositions remotely by video;
`
`WHEREAS, the parties agree that an extension of one month is necessary to coordinate
`
`and complete said depositions;
`
`
`1 Citations to the docket refer to docket entries in Case No. 14 Civ. 2396 (PGG-SN).
`
`
`
`
`1
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 212 Filed 05/26/20 Page 2 of 3
`
`
`
`WHEREAS, the parties have a disagreement concerning the appropriate deadlines for
`
`submission of letters seeking leave to file dispositive motions and oppositions thereto and
`
`previously agreed to submit either a joint stipulation reflecting their agreement or a joint letter
`
`setting forth their respective positions on the issue for resolution by the Court;
`
`NOW THEREFORE, the parties hereby stipulate and agree as follows:
`
`1.
`
`The parties must complete expert discovery, including depositions of experts,
`
`by July 31, 2020;
`
`2.
`
`The parties have not been able to resolve their disagreement concerning the
`
`appropriate deadlines for submission of letters seeking leave to file dispositive motions and
`
`oppositions thereto, and therefore shall submit a joint letter setting forth their respective
`
`positions on the issue for resolution by the Court no later than 45 days before the close of
`
`expert discovery.
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`Case 1:14-cv-02396-PGG-SN Document 212 Filed 05/26/20 Page 3 of 3
`
`
`
`SO STIPULATED.
`
`Dated: May 26, 2020
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`BY: /s/ Amy E. Hayden
`
`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)
`Jacob R. Buczko (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
`jbuczko@raklaw.com
`
`Charles R. Macedo
`AMSTER, ROTHSTEIN &
`EBENSTEIN LLP
`90 Park Avenue
`New York, NY 10016
`Phone: (212) 336-8074
`Fax: (212) 336-8001
`cmacedo@arelaw.com
`
`
`Attorneys for Network-1
`Technologies, Inc.
`
`
`
`
`
`
`
`
`
`WILLIAMS & CONNOLLY LLP
`
`BY: /s/ Samuel Bryant Davidoff
`
`Samuel Bryant Davidoff
`650 Fifth Avenue, Suite 1500
`New York, NY 10022
`212-688-9224
`sdavidoff@wc.com
`
`Bruce R. Genderson (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
`atrask@wc.com
`gsafty@wc.com
`sdang@wc.com
`
`Attorneys for Google LLC and
`YouTube, LLC
`
`
`
`
`
`
`
`
`SO ORDERED.
`
`Date: ___________________
`
`
`_________________________________
`Paul G. Gardephe
`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
