`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`MULTIMEDIA CONTENT
`MANAGEMENT LLC,
`Plaintiff
`
`V.
`
`DISH NETWORK L.L.C.,
`Defendant.
`
`§
`§
`§
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`§
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`§
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`§
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`§
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`§
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`§
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`Civil Action No.: 6:1 8-CV-00207-ADA
`
`JURY TRIAL DEMANDED
`
`PATENT CASE
`
`PLAINTIFF MULTIMEDIA CONTENT MANAGEMENT LLC AND
`DEFENDANT DISH NETWORK L.L.C.'S SCHEDULING ORDER
`
`Plaintiff Multimedia Content Management, LLC ("MCM") and Defendant DISH
`
`Network L.L.C. ("DISH"), by and through their respective counsel of record, respectfiully submit
`
`this Scheduling Order based on the dates assigned by the Court in its Scheduling Hearing (Dkt.
`
`No. 72).
`
`Proposed Scheduling Item
`Preliminary Infringement Contentions
`
`Fact Discovery opens; deadline to serve Initial
`Disclosures per Rule 26(a)
`
`Deadline to add parties
`
`Deadline to serve Final Infringement and Invalidity
`Contentions'
`
`Proposed Deadline
`May 15, 2019
`
`June 10, 2019
`
`June 21, 2019
`
`September 13, 2019
`
`Deadline to amend pleadings. A motion is not required
`unless the amendment adds patents.
`
`October 7, 2019
`
`Deadline to identify up to 6 asserted claims for the case December 1, 2019
`Close of Fact Discovery
`
`January 15, 2020
`
`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`The parties have discussed the issue of prior art that is public use, on-sale, or otherwise
`available to the public, and non-public inventions, and confirm the parties' understanding that
`the parties may supplement the identified prior art in the invalidity contentions with additional
`detail developed through fact discovery through the close of fact discovery.
`
`EXHIBIT 2009
`
`
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`8.
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`9.
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`10.
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`11.
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`12.
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`13.
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`14.
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`15.
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`16.
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`17.
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`18.
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`19.
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`Opening Expert Reports
`Rebuttal Expert Reports
`Close of Expert Discovery
`Dispositive motion deadline and Daubert motion
`deadline.
`Serve Pretrial Disclosures (jury instructions, exhibit
`lists, witness lists, designations)
`Serve objections to pretrial disclosures/rebuttal
`disclosures
`Serve objections to rebuttal disclosures and file motions
`in limine
`File Joint Pretrial Order and Pretrial Submissions (jury
`instructions, exhibit lists, witness lists, designations);
`file oppositions to motions in limine
`Deadline to meet and confer regarding remaining
`objections and disputes on motions in limine
`File joint notice identifying remaining objections to
`pretrial disclosures and disputes on motions in limine
`Final Pretrial Conference
`
`Jury SelectionlTrial
`
`February 6, 2020
`March 4, 2020
`March 20, 2020
`April 13, 2020
`
`May 8, 2020
`
`May 22, 2020
`
`June 1, 2020
`
`June 10, 2020
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`June 19, 2020
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`June 29, 2020
`
`On or around July 6,
`2020
`July 20, 2020
`
`EXHIBIT 2009
`
`
`
`Date: June 3, 2019
`
`Respectfully submitted,
`
`By: /s/Ali Dhanani
`G. Hopkins Guy, III (pro hac vice)
`BAKER Borrs L.L.P.
`1001 Page Mill Road,
`Building One, Suite 200
`Palo Alto, CA 94304
`Tel.: (650) 739-7500
`Fax: (650) 739-7699
`hop.guy@bakerbotts.com
`
`Au Dhanani (pro hac vice)
`Texas State Bar No. 24055400
`BAKER BOTTS L.L.P.
`910 Louisiana St.
`Houston, TX 77002
`Tel.: (713) 229-1108
`Fax: (713) 229-2808
`ali.dhanani@bakerbotts.com
`
`John P. Palmer
`State Bar No. 15430600
`NAMAN, HOWELL, SMITH & LEE, PLLC
`400 Austin Ave., Suite 800
`P.O. Box 1470
`Waco, Texas 76703
`Tel: (254) 755-4100
`Fax: (254) 754-6331
`palmer@namanhowell.com
`
`ATTORNEYS FOR DEFENDANT
`DISH NETWORK L.L. C.
`
`EXHIBIT 2009
`
`
`
`By: Is/Jeffrey G. Toler
`Jeffrey 0. Toler
`Texas State Bar No. 24011201
`Aakash S. Parekh
`Texas State Bar No. 24059133
`TOLER LAW GROUP, PC
`8500 Bluffstone Cove
`Suite A201
`Austin, TX 78759
`(512) 327-5515
`E-mail: jtoler@tlgiplaw.com
`E-mail: aparekhtlgiplaw.com
`
`ATTORNEYS FOR PLAINTIFF
`MULTIMEDIA CONTENT
`MANA GEMENT LL C
`
`:A
`
`'e
`
`04
`
`7..o4
`
`t:
`
`t\r;iv
`Jtrt.t Ski.c &tcb
`
`EXHIBIT 2009
`
`
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