`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`
`
`
`v.
`
`
`GOOGLE LLC,
`
`
`Plaintiff,
`
`Defendant,
`
`Case No. 1:22-cv-01331-MSN-JFA
`
`
`
`
`
`CONSENT MOTION FOR EXTENSION OF DEADLINE FOR
`REBUTTAL EXPERT DISCLOSURES AND MEMORANDUM IN
`SUPPORT
`
`Due to an unexpected family emergency involving one of Defendant Google’s principal
`
`attorneys in this matter, Defendant, Google LLC (“Google”), with the consent of Geoscope
`
`Technologies Pte. Ltd. (“Geoscope”), moves the Court to extend the deadline for the parties’
`
`Rebuttal Expert Disclosures by one week to August 4, 2023. The requested extension will not
`
`prejudice any party or delay or change any other dates in the Court’s Modified Scheduling Order
`
`(ECF No. 91). In support of this consent motion, Google states as follows:
`
`OTHER DATES, TERMS, AND PROVISIONS OF ORDERS NOT CHANGED
`
`1.
`
`On June 26, 2023, the Court entered the Court’s Modified Scheduling Order setting,
`
`among other dates, July 28, 2023 as the date for the parties to serve their Rebuttal Expert
`
`Disclosures. The Court set August 18, 2023 as the date for the close of Expert Discovery.
`
`2.
`
`One of Google’s principal lawyers involved in the preparation of the Google
`
`Rebuttal Expert Report has experienced a sudden family emergency. As a result of that emergency,
`
`Google requested and Geoscope agreed to move the date for the parties to serve their Rebuttal
`
`Expert Disclosures back by one week to August 4, 2023.
`
`
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 106 Filed 07/19/23 Page 2 of 3 PageID# 2033
`
`3.
`
`The parties do not propose to change either the fact-discovery cut-off (August 11,
`
`2023) or the date of the final pretrial conference (August 17, 2023, at 1:00 p.m.). Except for the
`
`requested extension as set out in the attached proposed order, the parties do not propose to change
`
`any other dates, terms, and provisions set in the Court’s prior scheduling orders.
`
`4.
`
`Google requests that this Court extend the date for the parties to serve their Rebuttal
`
`Expert Disclosures to and including August 4, 2023.
`
`5.
`
`Because the motion is agreed to, the parties waive a hearing on this procedural motion.
`
`Should the Court deem a hearing necessary, however, the parties will appear as directed.
`
`WHEREFORE, Google, with the consent of Geoscope, requests that this Court enter an
`
`order extending the deadline for the parties’ rebuttal expert disclosures. An Agreed proposed order
`
`is attached as Exhibit 1.
`
`
`
`
`
`2
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 106 Filed 07/19/23 Page 3 of 3 PageID# 2034
`
`
`Dated: July 19, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Stephen E. Noona
`
`Stephen E. Noona (VSB No. 25367)
`KAUFMAN & CANOLES, P.C.
`150 W. Main Street, Suite 2100
`Norfolk, VA 23510-1665
`Telephone: (757) 624-3239
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`
`
`Edward J. Bennett (VSB No. 40118)
`Adam D. Harber (pro hac vice)
`Andrew Trask (pro hac vice)
`Benjamin N. Hazelwood (VSB No. 96058)
`Michael Xun Liu (pro hac vice)
`Matthew W. Lachman (pro hac vice)
`Adam Pan (pro hac vice)
`Anna Searle (pro hac vice)
`WILLIAMS & CONNOLLY
`680 Maine Avenue SW
`Washington, DC 20024
`Telephone: (202) 434-5000
`ebennett@wc.com
`aharber@wc.com
`atrask@wc.com
`bhazelwood@wc.com
`mliu@wc.com
`mlachman@wc.com
`apan@wc.com
`asearle@wc.com
`
`Counsel for Google LLC
`
`21678511.v1
`
`3
`
`
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