Case 1:22-cv-01373-MSN-JFA Document 105 Filed 08/21/23 Page 1 of 3 PageID# 1983
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`
`
`
`v.
`
`
`APPLE INC.,
`
`
`Plaintiff,
`
`Defendant,
`
`Case No. 1:22-cv-01373-MSN-JFA
`
`
`
`
`
`
`
`JOINT MOTION TO CONTINUE DEADLINE FOR
`RULE 26(a)(3) PRETRIAL DISCLOSURES
`
`Plaintiff Geoscope Technologies Pte. Ltd. (“Geoscope”) and Defendant Apple Inc.
`
`(“Apple”) 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. Google LLC, No. 1:22-cv-1331-MSN-JFA (E.D.
`
`Va. filed Nov. 22, 2022) (“Google Action”). Certain proceedings in this action and the Google
`
`Action are coordinated. See, e.g., Dkt. No. 44, § VI (claim construction); Dkt. No. 82 (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. 39. The Court also ordered the parties to complete discovery,
`
`including expert discovery, by August 11, 2023. Id.
`
`
`
`1
`
`
`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`
`
`
`v.
`
`
`APPLE INC.,
`
`
`Plaintiff,
`
`Defendant,
`
`Case No. 1:22-cv-01373-MSN-JFA
`
`
`
`
`
`
`
`JOINT MOTION TO CONTINUE DEADLINE FOR
`RULE 26(a)(3) PRETRIAL DISCLOSURES
`
`Plaintiff Geoscope Technologies Pte. Ltd. (“Geoscope”) and Defendant Apple Inc.
`
`(“Apple”) 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. Google LLC, No. 1:22-cv-1331-MSN-JFA (E.D.
`
`Va. filed Nov. 22, 2022) (“Google Action”). Certain proceedings in this action and the Google
`
`Action are coordinated. See, e.g., Dkt. No. 44, § VI (claim construction); Dkt. No. 82 (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. 39. The Court also ordered the parties to complete discovery,
`
`including expert discovery, by August 11, 2023. Id.
`
`
`
`1
`
`
`
`Case 1:22-cv-01373-MSN-JFA Document 105 Filed 08/21/23 Page 2 of 3 PageID# 1984
`
`
`
`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. 80, ¶¶ 7–9. The parties also 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. 81 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. 102.
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`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
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`date for Rule 26(a)(3) disclosures, including but not limited to a list of the exhibits to be used at
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`trial, a list of the witnesses to be called at trial, and a written stipulation of uncontested facts, be
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`continued until ten (10) days after the final pretrial conference, or October 2, 2023, and that the
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`deadline for any objections thereto be continued until ten (10) days after the Rule 26(a)(3)
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`disclosures are filed, or October 12, 2023.
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`7.
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`The parties waive a hearing on this procedural motion.
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`WHEREFORE, Geoscope and Apple, in coordination with the Google Action, jointly request that
`
`this Court enter an order setting a new schedule for the parties’ Rule 26(a)(3) disclosures. A
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`proposed order is submitted herewith.
`
`
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`2
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`Case 1:22-cv-01373-MSN-JFA Document 105 Filed 08/21/23 Page 3 of 3 PageID# 1985
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`Respectfully submitted,
`
`Dated: August 21, 2023.
`
`
`/s/ John M. Erbach
`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.
`
`
`
`/s/ Craig C. Reilly
`Craig C. Reilly
`Craig C. Reilly (VSB # 20942)
`209 Madison Street, Suite 501
`Alexandria, Virginia 22314
`T: (703) 549-5354
`F: (703) 549-5355 E:
`craig.reilly@ccreillylaw.com
`
`Brian M. Buroker (VSB No. 39,581)
`bburoker@gibsondunn.com
`Wendy W. Cai (pro hac vice)
`wcai@gibsondunn.com
`David Brzozowski (pro hac vice)
`dbrzozowski@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Tel: (202) 955-8295
`Fax: (202) 831-6106
`
`Brian A. Rosenthal (pro hac vice)
`brosenthal@gibsondunn.com
`Gibson, Dunn & Crutcher LLP 200
`Park Avenue New York, New York 10166
`Tel: (212) 351-4000
`Fax: (212) 716-0839
`
`Jaysen S. Chung (pro hac vice)
`jschung@gibsondunn.com
`Andrew W. Robb (pro hac vice)
`arobb@gibsondunn.com
`Gibson, Dunn & Crutcher LLP 1881
`Page Mill Road Palo Alto, CA 94304-1211
`Tel: (650) 849-5300 Fax: (650) 849-5067
`
`Nathaniel R. Scharn (pro hac vice)
`nscharn@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`3161 Michelson Drive
`Irvine, CA 92612-4412
`Tel: (949) 451-3800
`Fax: (949) 451-4220
`Attorneys for Defendant Apple Inc.
`
`
`
`3
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`
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