`
`
`EXHIBIT A
`
`Proposed Schedule
`
`
`
`Event
`
`Anacor Proposed
`Date
`
`Mylan Proposed
`Date
`
`Scheduling conference
`
`Parties submit Discovery Confidentiality Order
`
`Plaintiff identifies accused product(s), the
`asserted patent(s) allegedly infringe(d), and
`produces the file history for each asserted patent
`
`Defendants produce core technical documents
`related to accused product(s), including the
`ANDA and any supplements or amendments
`thereto for the accused product
`
`Plaintiff produces initial claim chart(s) relating
`each known accused product to the asserted
`claims
`
`Defendants produce initial invalidity contentions
`for each claim and known invalidating references
`
`Exchange lists of claim terms in need of
`construction and respective proposed
`constructions
`
`Joint claim construction statement
`
`Plaintiff’s opening Markman brief
`
`Defendants’ answering Markman brief
`
`Deadline to join parties
`
`Deadline to amend pleadings
`
`Plaintiff’s reply Markman brief
`
`Thu, March 28, 2019
`
`Thu, April 18, 2019
`
`Fri, June 14, 2019
`
`Tue, July 2, 2019
`
`Fri, August 16, 2019
`
`Thu, September 26, 2019
`
`Fri, November 1, 2019
`
`Fri, November 15, 2019
`
`Fri, December 20, 2019
`
`Thu, January 31, 2020
`
`Thu, January 31, 2020
`
`Fri, February 28, 2020
`
`Fri, February 28, 2020
`
`Substantial completion of document production
`
`Fri, May 15, 2020 Fri, March 20, 2020
`
`Markman hearing
`
`Close of fact discovery
`
`At the Court’s
`convenience
`
`Fri, October 2,
`2020
`
`At the Court’s
`convenience
`May/June 2020
`
`Fri, June 19, 2020
`
`Expert reports for issues on which parties have
`the burden of proof
`
`Fri, November 13,
`2020
`
`Thu, July 2, 2020
`
`Rebuttal expert reports and objective indicia of
`non-obviousness
`
`Fri, January 15,
`2021
`
`Thu, July 30, 2020
`
`Defendants’ reply expert reports on objective
`indicia of non-obviousness
`
`Fri, February 12,
`2021
`
`Thu, August 27,
`2020
`
`Close of expert discovery
`
`Fri, April 16, 2021
`
`Fri, September 24,
`2020
`
`
`
`1
`
`
`
`Case 1:18-cv-00202-IMK Document 45-1 Filed 03/14/19 Page 2 of 2 PageID #: 1362
`
`
`EXHIBIT A
`
`Event
`
`Anacor Proposed
`Date
`
`Mylan Proposed
`Date
`
`Deadline to submit dispositive motions
`
`Deadline to submit response to dispositive
`motions
`
`Deadline to submit reply to dispositive motions
`
`Pretrial disclosures (witness list, deposition
`designations, exhibit list) by the party with the
`burden of proof
`
`Objections and counterdesignations to pretrial
`disclosures; rebuttal pretrial disclosures
`
`No Date
`Appropriate
`
`No Date
`Appropriate
`
`No Date
`Appropriate
`
`Tue, December 29,
`2020
`
`Thu, January 14,
`2021
`
`Thu, January 28,
`2021
`(3 months prior to
`pretrial)
`
`1 week prior to
`objections and
`counterdesignations
`to pretrial
`disclosures
`
`1 week prior to
`objections and
`counterdesignations
`to pretrial
`disclosures
`
`1 week prior to
`rebuttal pretrial
`disclosures
`
`1 week prior to
`rebuttal pretrial
`disclosures
`
`Objections to rebuttal pretrial disclosures;
`motions in limine
`
`1 week prior to
`joint pretrial order
`
`1 week prior to
`joint pretrial order
`
`Joint pretrial order; oppositions to motions in
`limine
`
`Fri, May 14, 2021
`
`Pretrial conference
`
`Trial
`
`
`
`At the Court’s
`convenience
`
`At the Court’s
`convenience
`
`1 week prior to
`pretrial conference
`
`2 weeks prior to
`trial
`
`At the Court’s
`convenience May
`2021
`
`
`
`2
`
`
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