`
`
`
`
`
`Exhibit A
`
`Parties’ Proposed Pre-Trial and Trial Schedule for
`Samsung’s Claims against Defendants
`
`
`
`
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 96-1 Filed 04/21/15 Page 2 of 4 PageID# 15325
`
`
`
`
`Event
`
`File Protective Order
`
`Date
`April 20, 2015
`
`Deadline to Provide Initial Infringement Contentions
`
`April 21, 2015
`
`Rule 26(a)(1) Initial Disclosures
`
`April 24, 2015
`
`Deadline for Defendants to produce documents sufficient
`to show the operation of the accused instrumentalities (to
`the extent such documents are in Defendants’ possession,
`custody, or control)
`
`May 13, 2015
`
`Deadline to Provide Invalidity Contentions
`
`May 8, 2015
`
`Exchange List of Proposed Claim Terms for
`Construction
`
`First Asserted Claim Selection
`
`48 total claims, limit 10 per patent
`
`Exchange Revised List of Proposed Claim Terms for
`Construction
`
`Exchange proposed constructions for claim terms on the
`revised lists of claim terms for construction and
`supporting evidence for those constructions
`
`May 15, 2015
`
`May 20, 2015
`
`
`
`May 22, 2015
`
`May 25, 2015
`
`Deadline for Parties to Discuss Settlement and Report to
`Court regarding Same
`
`May 27, 2015
`
`First Invalidity Reference Selection
`
`60 total references, limit 12 per patent
`
`May 27, 2015
`
`Exchange and File Final Constructions
`
`May 29, 2015
`
`Tutorial
`
`Opening Claim Construction Brief
`
`Responsive Claim Construction Brief
`
`June 3, 2015 at 10:00 AM
`
`June 5, 2015
`
`June 12, 2015
`
`Markman Hearing
`
`June 22, 2015 at 10:00 AM
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 96-1 Filed 04/21/15 Page 3 of 4 PageID# 15326
`
`
`Event
`Second Asserted Claim Selection and Amended
`Infringement Contentions
`
`24 total claims, limit 5 per patent
`
`Second Invalidity Reference Selection
`
`30 total references, limit 6 per patent
`
`Exchange initial expert reports
`
`Exchange rebuttal expert reports
`
`Date
`
`7 days after the Court issues its
`Claim Construction Order
`
`7 days after Samsung’s Second
`Election of Asserted Claims
`
`September 18, 2015
`
`October 9, 2015
`
`Conclusion of all discovery, including expert discovery
`and expert depositions
`
`October 30, 2015
`
`Deadline for filing Summary Judgment Motions
`
`November 5, 2015
`
`Motions in Limine
`
`Opposition to Motions in Limine
`
`November 10, 2015
`
`November 18, 2015
`
`Written Stipulations of Uncontroverted Facts Meet and
`Confer
`
` (24 days before pretrial)
`
`List of All Discovery Materials to be Offered at Trial to
`be Served (Includes Deposition Designations and
`Summaries of Same)
`
` (21 days before pretrial)
`
`Replies in support of Motions in Limine
`
`November 25, 2015
`
`Plaintiff’s Witness Call List to be Filed
`
`Plaintiff’s Proposed Exhibit List Due
`
` (18 days before pretrial)
`
`(18 days before pretrial)
`
`Plaintiff’s Exhibits to be Delivered to Opposing Counsel
`
`(18 days before pretrial)
`
`Defendants’ Witness Call List to be Filed
`
`Defendants’ Proposed Exhibit List Due
`
`Defendants’ Exhibits to be Delivered to Opposing
`Counsel
`
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`(16 days before pretrial)
`
`Summary Judgment Hearing, if desired
`
`(15 days before pretrial)
`
`
`
`Case 3:14-cv-00757-REP-DJN Document 96-1 Filed 04/21/15 Page 4 of 4 PageID# 15327
`
`
`Event
`Rebuttal Designations and Amended Summaries to be
`Served
`
`Date
`
`(14 days before pretrial)
`
`Hearing on Motions in Limine (if desired)
`
`December 2, 2015
`
`Objections to Exhibits to be Filed with Clerk
`
`(12 days before pretrial)
`
`Written stipulations of uncontroverted facts signed by
`Counsel and Filed with Clerk
`
`(11 days before pretrial)
`
`Any Objection to Designations Due
`
`(11 days before pretrial)
`
`Proposed Jury Instructions and Proposed Verdict Form
`Due to Clerk
`
`(10 days before pretrial)
`
`Confer to Resolve Objections to Discovery Designations
`
`(9 days before pretrial)
`
`Objections to Proposed Jury Instructions Due
`
`(7 days before pretrial)
`
`Proposed Voir Dire Due to Clerk and Delivered to
`Opposing Counsel
`
`(7 days before pretrial)
`
`Filing of Discovery Designations (Conformed Version)
`to Opposing Counsel, Clerk and the Court
`
`(5 days before pretrial)
`
`Consolidated and Agreed to Jury Instructions Due
`
`(4 days before pretrial)
`
`Set of Disputed Instructions with Brief Statement of
`Reasons of Dispute Due
`
`Objections to Voir Dire Filed
`
`Summaries of Deposition Testimony to which No
`Objection Has Been Made to Be Filed with Clerk
`
`Exhibits to Be Delivered to Clerk (Two Sets, Pre-
`Marked, Indexed)
`
` (4 days before pretrial)
`
` (3 days before pretrial)
`
` (2 days before pretrial)
`
`(1 day before pretrial)
`
`Final Pre-Trial Conference
`
`December 15, 2015 at 10:00 AM
`
`Jury Selection
`
`Trial
`
`January 7, 2016 at 9:30 AM
`
`January 11, 2016 at 9:30 AM
`
`
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