1 2 3 4 5 6 7 8 9 Plaintiff United States of America and Defendants Hewlett Packard Enterprise Co. (“HPE”) and Juniper Networks, Inc. (“Juniper”), jointly submit this Joint Proposed Case Management Plan pursuant to the Standing Order for All Judges of the Northern District of California and Civil Local Rule 16-9, and the Court’s order at the Case Management Conference on February 28, 2025.
Notwithstanding any other part of this Paragraph, the Parties reserve their right to move for a protective order pursuant to Federal Rule of Civil Procedure 26(c)(1).
Budgets, invoices, bills, receipts, or time records concerning testifying or non-testifying experts, their staff, assistants, colleagues, or associates, or their companies or organizations.
Notwithstanding the limitations contained in the paragraph immediately above, an expert may be asked at a deposition or trial: (a) to identify and generally describe what data, facts, algorithms, modeling, regression analyses and source code the expert reviewed, investigated or considered but did not rely on or otherwise use, and (b) to describe the reasons for reviewing—but not using or relying on—any such data, facts, algorithms, modeling, analyses or source code.
D. Service of Pleadings and Discovery on Other Parties Service of all pleadings, discovery requests (including subpoenas for testimony or documents under Federal Rule of Civil Procedure 45), and delivery of all correspondence in this matter, other than expert backup materials, must be made by ECF or email, except when the volume of attachments requires delivery via secure file transfer, to the following individuals designated by each Party: