`
`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
`
`
`
`
`
`
`
`JOINT MOTION AND MEMORANDUM IN SUPPORT OF JOINT
`MOTION TO CONTINUE DEADLINE FOR RULE 26(a)(3) PRETRIAL
`DISCLOSURES
`
`Plaintiff Geoscope Technologies Pte. Ltd. (“Geoscope”) and Defendant Google LLC
`
`(“Google”) jointly move the Court to continue the deadline for the parties’ Rule 26(a)(3) pretrial
`
`disclosures.
`
`1.
`
`This is an action for patent infringement. There is pending before the Court a
`
`separate patent infringement action in which Geoscope has asserted the same patents against
`
`another party. Geoscope Technologies Pte Ltd. v. Apple Inc., No. 1:22-cv-1373-MSN-JFA (E.D.
`
`Va. filed Dec. 1, 2022) (“Apple Action”). Certain proceedings in this action and the Apple Action
`
`are coordinated. See, e.g., Dkt. No. 50, § VI (claim construction); Dkt. No. 91 (motion for
`
`judgment on the pleadings).
`
`2.
`
`Under the original schedule set by the Court, the parties’ Rule 26(a)(3) pretrial
`
`disclosures were due on or before August 17, 2023, which at the time was the date of the final
`
`pretrial conference. Dkt. No. 49. The Court also ordered the parties to complete discovery,
`
`including expert discovery, by August 11, 2023. Id.
`
`
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 115 Filed 08/21/23 Page 2 of 3 PageID# 2156
`
`
`
`3.
`
`On June 21, 2023, given the complex factual and technical issues in this action, the
`
`parties requested that the deadline for filing and serving their Rule 26(a)(3) pretrial disclosures be
`
`continued until a date that the parties would propose jointly at or before the final pretrial conference.
`
`Dkt. No. 88, ¶¶ 7–9. The parties simultaneously moved for leave to complete expert depositions
`
`by August 18, 2023. Id., ¶ 2.
`
`4.
`
`On June 26, 2023, the Court granted the parties’ request to extend the deadline to
`
`complete expert depositions until August 18, 2023. Dkt. No. 91 at 1. The Court also continued
`
`the deadlines for the parties’ Rule 26(a)(3) disclosures until ten (10) days after the cut-off for
`
`expert discovery, or August 28, 2023. Id. at 2.
`
`5.
`
`On August 15, 2023, the Court continued the final pretrial conference from August
`
`17, 2023, to September 21, 2023 at 1:00 p.m. Dkt. No. 113.
`
`6.
`
`In light of the continuance of the final pretrial conference, and to allow time for
`
`mature consideration when designating trial evidence, the parties respectfully request that the due
`
`date for Rule 26(a)(3) disclosures, including but not limited to a list of the exhibits to be used at
`
`trial, a list of the witnesses to be called at trial, and a written stipulation of uncontested facts, be
`
`continued until ten (10) days after the final pretrial conference, or October 2, 2023, and that the
`
`deadline for any objections thereto be continued until ten (10) days after the Rule 26(a)(3)
`
`disclosures are filed, or October 12, 2023.
`
`7.
`
`The parties waive a hearing on this procedural motion.
`
`WHEREFORE, Geoscope and Google, in coordination with the Apple Action, jointly
`
`request that this Court enter an order setting a new schedule for the parties’ Rule 26(a)(3)
`
`disclosures. A proposed order is submitted herewith as Exhibit 1.
`
`
`
`
`
`
`
`2
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 115 Filed 08/21/23 Page 3 of 3 PageID# 2157
`
`
`
`
`
`
`
`Dated: August 21, 2023
`
`
`/s/ John M. Erbach
`John M. Erbach (VSB No. 76695)
`Chris Bascom (VSB No. 87302)
`SPOTTS FAIN, P.C.
`Renaissance Centre
`411 East Franklin Street, Suite 600
`Richmond, Virginia 23219
`Tel: (804) 697-2044
`Fax: (804) 697-2144
`jerbach@spottsfain.com
`cbascom@spottsfain.com
`
`Timothy K. Gilman (pro hac vice)
`Saunak K. Desai (pro hac vice)
`Gregory R. Springsted (pro hac vice)
`Alexandra J. Cho (pro hac vice)
`SCHULTE ROTH & ZABEL LLP
`919 Third Avenue
`New York, NY 10022
`Tel: (212) 756-2000
`Fax: (212) 593-5955
`tim.gilman@srz.com
`saunak.desai@srz.com
`gregory.springsted@srz.com
`alexandra.cho@srz.com
`
`Attorneys for Plaintiff Geoscope
`Technologies Pte. Ltd.
`
`
`
` Respectfully submitted,
`
`/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)
`Adam Pan (pro hac vice)
`WILLIAMS & CONNOLLY LLP
`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
`apan@wc.com
`
`
`Attorneys for Defendant Google LLC
`
`21768046.v1
`
`3
`
`
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