Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 1 of 15 PageID #: 155
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`TERRACON CONSULT ANTS, INC .,
`
`V.
`
`NV5, INC.,
`
`Plaintiff,
`
`Defendant.
`
`)
`)
`)
`)
`) C.A. No. 21-100 (LPS)
`)
`)
`)
`)
`
`PROPOSED PATENT SCHEDULING ORDER
`
`This),.~ day of June, 2021, the parties having determined after discussion that the
`
`matter cannot be resolved at this juncture by settlement, voluntary mediation, or binding
`
`arbitration;
`
`IT IS HEREBY ORDERED that:
`
`1.
`
`Rule 26(a)(l) Initial Disclosures and E-Discovery Default Standard. Plaintiff
`
`previously served its initial disclosures on January 26, 2021. Unless otherwise agreed to by the
`
`parties, the Defendant shall make its initial disclosures pursuant to Federal Rule of Civil
`
`Procedure 26(a)(l) within five (5) days of the date of this Order. If they have not already done
`
`so, the parties are to review the Court's Default Standard for Discovery, Including Discovery of
`
`Electronically Stored Information ("ESI") (which is posted at http://www.ded.uscourts.gov; see
`
`Other Resources, Default Standards for Discovery, and is incorporated herein by reference).
`
`Exhibit - 1015
`NV5, Inc. v. Terracon Consultants, Inc.
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 2 of 15 PageID #: 156
`
`2.
`
`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
`
`parties, and to amend or supplement the pleadings, shall be filed on or before November 25,
`
`2021.
`
`3.
`
`Application to Court for Protective Order. The parties previously entered into an
`
`Agreed Protective Order, which was entered by the District Court for the Southern District of
`
`Texas on January 15, 2021. Doc. No. 37. The protective order includes in part the following
`
`paragraph:
`
`Other Proceedings. By entering this Protective Order and limiting
`the disclosure of information in this case, the presiding judge 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 Protective Order who may be subject
`to a motion to disclose another party's information designated
`"Confidential" or "Highly Confidential" pursuant to this Protective
`Order must 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.
`
`4.
`
`Papers Filed Under Seal. In accordance with section G of the Administrative
`
`Procedures Governing Filing and Service by Electronic Means, a redacted version of any sealed
`
`document shall be filed electronically within seven (7) days of the filing of the sealed document.
`
`Should any party intend to request to seal or redact all or any portion of a transcript of a
`
`court proceeding (including a teleconference), such party should expressly note that intent at the
`
`start of the court proceeding. Should the party subsequently choose to make a request for sealing
`
`or redaction, it must, promptly after the completion of the transcript, file with the Court a motion
`
`for sealing/redaction, and include as attachments (1) a copy of the complete transcript
`
`highlighted so the Court can easily identify and read the text proposed to be sealed/redacted, and
`
`(2) a copy of the proposed redacted/sealed transcript. With their request, the party seeking
`
`redactions must demonstrate why there is good cause for the redactions and why disclosure of
`
`- 2 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 3 of 15 PageID #: 157
`
`the redacted material would work a clearly defined and serious injury to the party seeking
`
`redaction.
`
`5.
`
`Courtesy Copies. Other than with respect to "discovery matters," which are
`
`governed by paragraph 8(g), and the final pretrial order, which is governed by paragraph 20, the
`
`parties shall provide to the Court two (2) courtesy copies of all briefs and one (1) courtesy copy
`
`of any other document filed in support of any briefs (i.e., appendices, exhibits, declarations,
`
`affidavits etc.). This provision also applies to papers filed under seal.
`
`6.
`
`ADR Process. This matter is referred to a magistrate judge to explore the
`
`possibility of alternative dispute resolution.
`
`7.
`
`Disclosures. Absent agreement among the parties, and approval of the Court:
`
`a.
`
`Plaintiff previously identified the accused product(s), including accused
`
`methods and systems, as well as the asserted patent(s) that the accused product(s) allegedly
`
`infringe(s) in infringement contentions and claim charts previously served on January 8, 2021
`
`and in Plaintiffs initial disclosures previously served on January 26, 2021. Plaintiff also
`
`previously produced the file history for each asserted patent on January 8, 2021.
`
`b.
`
`By June 28, 2021, Defendant shall produce core technical documents
`
`related to the accused product(s), sufficient to show how the accused product(s) work(s),
`
`including but not limited to non-publicly available operation manuals, product literature,
`
`schematics, and specifications. Defendant shall also produce sales figures for the accused
`
`product(s).
`
`c.
`
`By July 28, 2021 , Plaintiff shall produce an amended claim chart relating
`
`each known accused product to the asserted claims each such product allegedly infringes.
`
`- 3 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 4 of 15 PageID #: 158
`
`d.
`
`By September 1, 2021, Defendant shall produce its initial invalidity
`
`contentions for each asserted claim, as well as the known related invalidating references.
`
`e.
`
`By 30 days after the Markman order, Plaintiff shall provide final
`
`infringement contentions.
`
`f.
`
`By 14 days after Plaintiff provides final infringement contentions,
`
`Defendant shall provide final invalidity contentions.
`
`8.
`
`Discovery. Unless otherwise ordered by the Court, the limitations on discovery
`
`set forth in Local Rule 26.1 shall be strictly observed.
`
`a.
`
`Discovery Cut Off. All fact discovery in this case shall be initiated so that
`
`it will be completed on or before February 21, 2022. All expert discovery in this case shall be
`
`initiated so that it will be completed on or before July 9, 2022.
`
`b.
`
`Document Production. Document production shall be substantially
`
`complete by November 20, 2021.
`
`C.
`
`Requests for Admission. A maximum of 50 requests for admission are
`
`permitted for each side, except with respect to requests related to admissibility or authenticity
`
`(subject to a claim of undue burden).
`
`d.
`
`Interrogatories.
`
`1.
`
`A maximum of 25
`
`interrogatories,
`
`including contention
`
`interrogatories, are permitted for each side.
`
`11.
`
`The Court encourages the parties to serve and respond to
`
`contention interrogatories early in the case. In the absence of agreement among the parties,
`
`contention interrogatories, if filed, shall first be addressed by the party with the burden of proof.
`
`- 4 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 5 of 15 PageID #: 159
`
`The adequacy of all interrogatory answers shall be judged by the level of detail each party
`
`provides; i.e., the more detail a party provides, the more detail a party shall receive.
`
`e.
`
`Depositions.
`
`l.
`
`Limitation on Hours for Deposition Discovery. Each side is limited
`
`to a total of70 hours of taking testimony by deposition upon oral examination.
`
`11.
`
`Location of Depositions. Any party or representative ( officer,
`
`director, or managing agent) of a party filing a civil action in this district court must ordinarily be
`
`required, upon request, to submit to a deposition at a place designated within this district.
`
`Exceptions to this general rule may be made by order of the Court. A defendant who
`
`becomes a counterclaimant, cross-claimant, or third-party plaintiff shall be considered as having
`
`filed an action in this Court for the purpose of this provision.
`
`f.
`
`Disclosure of Expert Testimony.
`
`1.
`
`Expert Reports. For the party who has the initial burden of proof
`
`on the subject matter, the initial Federal Rule 26(a)(2) disclosure of expert testimony is due on or
`
`before April 5, 2022. The supplemental disclosure to contradict or rebut evidence on the same
`
`matter identified by another party is due on or before May 13, 2022. Reply expert reports from
`
`the party with the initial burden of proof are due on or before June 3, 2022. No other expert
`
`reports will be permitted without either the consent of all parties or leave of the Court. Along
`
`with the submissions of the expert reports, the parties shall advise of the dates and times of their
`
`experts' availability for deposition.
`
`11.
`
`Expert Report Supplementation. The parties agree they will permit
`
`expert declarations to be filed in connection with motions briefing (including case-dispositive
`
`motions), within the scope of their expert disclosures.
`
`- 5 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 6 of 15 PageID #: 160
`
`iii.
`
`Objections to Expert Testimony. To the extent any objection to
`
`expert testimony is made pursuant to the principles announced in Daubert v. Merrell Dow
`
`Pharm., Inc., 509 U.S. 579 (1993), as incorporated in Federal Rule of Evidence 702, it shall be
`
`made by motion no later than the deadline for dispositive motions set forth herein, unless
`
`otherwise ordered by the Court. Briefing on such motions is subject to the page limits set out in
`
`connection with briefing of case dispositive motions.
`
`g.
`
`Discovery Matters and Disputes Relating to Protective Orders.
`
`1.
`
`Any discovery motion filed without first complying with the
`
`following procedures will be denied without prejudice to renew pursuant to these procedures.
`
`11.
`
`Should counsel find, after good faith efforts -
`
`including verbal
`
`communication among Delaware and Lead Counsel for all parties to the dispute -
`
`that they are
`
`unable to resolve a discovery matter or a dispute relating to a protective order, the parties
`
`involved in the discovery matter or protective order dispute shall submit a joint letter in
`
`substantially the following form:
`
`Dear Judge Stark:
`
`The parties in the above- referenced matter write to request the
`scheduling of a discovery teleconference.
`
`The following attorneys, including at least one Delaware Counsel
`and at least one Lead Counsel per party, participated in a verbal
`meet-and-confer (in person and/or by telephone) on the following
`date(s):
`
`Delaware Counsel: ________ _
`
`Lead Counsel: _____________ _
`
`The disputes requiring judicial attention are listed below:
`
`- 6 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 7 of 15 PageID #: 161
`
`[provide here a non-argumentative list of disputes requiring
`judicial attention]
`
`111.
`
`On a date to be set by separate order, generally not less than forty-
`
`eight ( 48) hours prior to the conference, the party seeking relief shall file with the Court a letter,
`
`not to exceed three (3) pages, outlining the issues in dispute and its position on those issues. On a
`
`date to be set by separate order, but generally not less than twenty-four (24) hours prior to the
`
`conference, any party opposing the application for relief may file a letter, not to exceed three (3)
`
`pages, outlining that party's reasons for its opposition.
`
`iv.
`
`Each party shall submit two (2) courtesy copies of its discovery
`
`letter and any attachments.
`
`v.
`
`Should the Court find further briefing necessary upon conclusion
`
`of the telephone conference, the Court will order it. Alternatively, the Court may choose to
`
`resolve the dispute prior to the telephone conference and will, in that event, cancel the
`
`conference.
`
`9.
`
`Motions to Amend.
`
`a.
`
`Any motion to amend (including a motion for leave to amend) a pleading
`
`shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not
`
`to exceed three (3) pages, describing the basis for the requested relief, and shall attach the
`
`proposed amended pleading as well as a "blackline" comparison to the prior pleading.
`
`b.
`
`Within seven (7) days after the filing of a motion in compliance with this
`
`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
`
`pages.
`
`- 7 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 8 of 15 PageID #: 162
`
`c.
`
`Within three (3) days thereafter, the moving party may file a reply letter,
`
`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
`
`teleconference to address the motion to amend.
`
`10. Motions to Strike.
`
`a.
`
`Any motion to strike any pleading or other document shall NOT be
`
`accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed
`
`three (3) pages, describing the basis for the requested relief, and shall attach the document to be
`
`stricken.
`
`b.
`
`Within seven (7) days after the filing of a motion in compliance with this
`
`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
`
`pages.
`
`c.
`
`Within three (3) days thereafter, the moving party may file a reply letter,
`
`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
`
`teleconference to address the motion to strike.
`
`11.
`
`Tutorial Describing the Technology and Matters in Issue. Unless otherwise
`
`ordered by the Court, the parties shall provide the Court, no later than the date on which their
`
`opening claim construction briefs are due, a tutorial on the technology at issue. In that regard, the
`
`parties may separately or jointly submit a DVD of not more than thirty (30) minutes. The tutorial
`
`should focus on the technology in issue and should not be used for argument. The parties may
`
`choose to file their tutorial(s) under seal, subject to any protective order in effect. Each party may
`
`comment, in writing (in no more than five (5) pages) on the opposing party's tutorial. Any such
`
`comment shall be filed no later than the date on which the answering claim construction briefs
`
`- 8 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 9 of 15 PageID #: 163
`
`are due. As to the format selected, the parties should confirm the Court's technical abilities to
`
`access the information contained in the tutorial ( currently best are "mpeg" or "quicktime").
`
`12.
`
`Claim Construction Issue Identification. On September 28, 2021, 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). This document will not be filed with the
`
`Court. On October 5, 2021, the parties shall exchange their proposed claim construction of
`
`those term(s)/phrase(s). Subsequent to exchanging that list, the parties will meet and confer to
`
`prepare a Joint Claim Construction Chart to be submitted on October 12, 2021. The parties'
`
`Joint Claim Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s)
`
`in issue, and should include each party's proposed construction of the disputed claim language
`
`with citation(s) only to the
`
`intrinsic evidence in support of their respective proposed
`
`constructions. A copy of the patent(s) in issue as well as those portions of the intrinsic record
`
`relied upon shall be submitted with this Joint Claim Construction Chart. In this joint submission,
`
`the parties shall not provide argument.
`
`13.
`
`Claim Construction Briefing. The Plaintiff shall serve, but not file, its opening
`
`brief, not to exceed 20 pages, on October 26, 2021. The Defendant shall serve, but not file, its
`
`answering brief, not to exceed 30 pages, on November 23, 2021. The Plaintiff shall serve, but
`
`not file, its reply brief, not to exceed 20 pages, on December 17, 2021. The Defendant shall
`
`serve, but not file, its sur-reply brief, not to exceed 10 pages, on January 12, 2022. No later than
`
`January 19, 2022, the parties shall file a Joint Claim Construction Brief. The parties shall copy
`
`and paste their untitled briefs into one brief, with their positions on each claim term in sequential
`
`order, in substantially the form below:
`
`- 9 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 10 of 15 PageID #: 164
`
`JOINT CLAIM CONSTRUCTION BRIEF
`
`I. Representative Claims
`
`II. Agreed-upon Constructions
`
`III. Disputed Constructions
`
`A.
`
`[TERM 1]
`
`1. Plaintiffs Opening Position
`
`2. Defendant' s Answering Position
`
`3. Plaintiffs Reply Position
`
`4. Defendant's Sur-Reply Position
`
`B.
`
`[TERM 2]
`
`1. Plaintiffs Opening Position
`
`2. Defendant' s Answering Position
`
`3. Plaintiffs Reply Position
`
`4. Defendant's Sur-Reply Position
`
`The parties need not include any general summaries of the law relating to claim
`
`construction. If there are any materials that would be submitted in an index, the parties shall
`
`submit them in a Joint Appendix.
`
`14.
`
`Hearing on Claim Construction. Beginning at 9:00 a.m. on February 7, 2022, the
`
`Court will hear argument on claim construction. The parties shall notify the Court, by joint letter
`
`submission, no later than the date on which their answering claim construction briefs are due:
`
`(i) whether they request leave to present testimony at the hearing; and (ii) the amount of time
`
`they are requesting be allocated to them for the hearing.
`
`- 10 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 11 of 15 PageID #: 165
`
`Provided that the parties comply with all portions of this Scheduling Order, and any other
`
`orders of the Court, the parties should anticipate that the Court will issue its claim construction
`
`order within sixty (60) days of the conclusion of the claim construction hearing. If the Court is
`
`unable to meet this goal, it will advise the parties no later than sixty (60) days after the
`
`conclusion of the claim construction hearing.
`
`15.
`
`Interim Status Report. On February 7, 2022, counsel shall submit a joint letter to
`
`the Court with an interim report on the nature of the matters in issue and the progress of
`
`discovery to date. Thereafter, if the Court deems it necessary, it will schedule a status
`
`conference.
`
`16.
`
`Supplementation. Absent agreement among the parties, and approval of the Court,
`
`no later than the dates set for final infringement and invalidity contentions, the parties must
`
`finally supplement, inter alia, the identification of all accused products and of all invalidity
`
`references.
`
`17.
`
`Case Dispositive Motions. All case dispositive motions, an opening brief, and
`
`affidavits, if any, in support of the motion shall be served and filed on or before August 3,
`
`2022. Briefing will be presented pursuant to the Court' s Local Rules, as modified by this
`
`Order.
`
`a.
`
`No early motions without leave. No case dispositive motion under Rule 56
`
`may be filed more than ten (10) days before the above date without leave of the Court.
`
`b.
`
`Page limits combined with Daubert motion page limits. Each party is
`
`permitted to file as many case dispositive motions as desired; provided, however, that each SIDE
`
`will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40
`
`pages for all answering briefs, and a combined total of 20 pages for all reply briefs regardless of
`
`- 11 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 12 of 15 PageID #: 166
`
`the number of case dispositive motions that are filed. In the event that a party files , in addition to
`
`a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an
`
`expert's testimony, the total amount of pages permitted for all case dispositive and Daubert
`
`motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs,
`
`and 25 pages for all reply briefs for each SIDE. 1
`
`C.
`
`Hearing. The Court will hear argument on all pending case dispositive and
`
`Daubert motions on November 1, 2022 beginning at 9:00 a.m.
`
`Subject to further order of the Court, each side will be allocated a total of forty-five ( 45)
`
`minutes to present its argument on all pending motions .
`
`18.
`
`Applications by Motion. Except as otherwise specified herein, any application to
`
`the Court shall be by written motion filed with the Clerk. Any non-dispositive motion should
`
`contain the statement required by Local Rule 7.1.1.
`
`19.
`
`Pretrial Conference. On January 27, 2023, the Court will hold a pretrial
`
`conference m Court with counsel beginning at 2:00 p.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 with the information required by the form of Revised Final
`
`Pretrial Order -- Patent, which can be found on the Court's website (www.ded.uscourts.gov), on or
`
`before January 17, 2023 . 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 the joint
`
`proposed final pretrial order.
`
`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.
`
`- 12 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 13 of 15 PageID #: 167
`
`The parties shall provide the Court two (2) courtesy copies of the joint proposed final
`
`pretrial order and all attachments.
`
`As noted in the Revised Final Pretrial Order - Patent, the parties shall include in their
`
`joint proposed final pretrial order, among other things:
`
`a.
`
`a request for a specific number of hours for their trial presentations, as
`
`well as a requested number of days, based on the assumption that in a typical jury trial day (in
`
`which there is not jury selection, jury instruction, or deliberations), there will be 5 ½ to 6 ½
`
`hours of trial time, and in a typical bench trial day there will be 6 to 7 hours of trial time;
`
`b.
`
`their position as to whether the Court should allow objections to efforts to
`
`impeach a witness with prior testimony, including objections based on lack of completeness
`
`and/or lack of inconsistency;
`
`C.
`
`their position as to whether the Court should rule at trial on objections to
`
`expert testimony as beyond the scope of prior expert disclosures, taking time from the parties '
`
`trial presentation to argue and decide such objections, or defer ruling on all such objections
`
`unless renewed in writing following trial, subject to the proviso that a party prevailing on such a
`
`post-trial objection will be entitled to have all of its costs associated with a new trial paid for by
`
`the party that elicited the improper expert testimony at the earlier trial; and
`
`d.
`
`their position as to how to make motions for judgment as a matter of law,
`
`whether it be immediately at the appropriate point during trial or at a subsequent break, whether
`
`the jury should be in or out of the courtroom, and whether such motions may be supplemented in
`
`writing.
`
`20. Motions in Limine. Motions in limine shall not be separately filed. All in /imine
`
`requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall
`
`- 13 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 14 of 15 PageID #: 168
`
`be limited to three (3) in limine requests, unless 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 and may be opposed by a maximum of
`
`three (3) pages of argument, and the side making the in limine request may add a maximum of
`
`one (I) additional page in reply in support of its request. If more than one party is supporting or
`
`opposing an in limine request, such support or opposition shall be combined in a single three (3)
`
`page submission (and, if the 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 otherwise
`
`permitted by the Court.
`
`21.
`
`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a case is to be
`
`tried to a jury, pursuant to Local Rules 4 7 and 51 the parties should file (i) proposed voir dire,
`
`(ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms
`
`three (3) business days before the final pretrial conference. This submission shall be
`
`accompanied by a courtesy copy containing electronic
`
`files of these documents, m
`
`WordPerfect or Microsoft Word format, which may be submitted by e-mail to Judge Stark' s
`
`staff.
`
`22.
`
`Trial. This matter is scheduled for a seven (7) day jury trial beginning at 9:30 a.m .
`
`on February 6, 2023, with the subsequent trial days beginning at 9:00 a.m. Until the case
`
`is submitted to the jury for deliberations, the jury will be excused each day at 4:30 p.m. The
`
`trial will be timed, as counsel will be allocated a total number of hours in which to present
`
`their respective cases.
`
`23.
`
`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
`
`- 14 -
`
`

`

`Case 1:21-cv-00100-LPS Document 57 Filed 06/04/21 Page 15 of 15 PageID #: 169
`
`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.
`
`24.
`
`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 filed by that side, no matter how many such motions are
`
`filed.
`
`- 15 -
`
`