Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 1 of 15 PageID #: 693
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`CHERVON (HK) LIMITED,
`CHERVON NORTH AMERICA INC.,
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`Plaintiffs,
`
`V.
`
`ONE WORLD TECHNOLOGIES, INC.,
`TECHTRONIC INDUSTRIES CO.
`LTD.,
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`Def endants.
`
`)
`)
`)
`) C.A. No. 19-1293-LPS
`)
`)
`)
`)
`)
`)
`)
`)
`
`This '\i ~
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`[PROPOSED) SCHEDULING ORDER
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`y of ~ 20")/f the Court having conducted a Case Management
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`Conference/Rule 16 scheduling and planning conference pursuant to Local Rule 16.2(a) and
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`Judge Stark' s Revised Procedures
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`for Managing Patent Cases
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`(which
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`is posted at
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`http: //www.ded.uscourts.gov,; see Chambers, Judge Leonard P. Stark, Patent Cases) on February
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`27, 2020, and the parties having determined after discussion that the matter cannot be resolved at
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`this juncture by settlement, voluntary mediation, or binding arbitration;
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`IT IS HEREBY ORDERED that:
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`1.
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`Rule 26(a)(l) Initial Disclosures and E-Discovery Default Standard. Unless
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`otherwise agreed to by the parties, the parties shall make their initial disclosures pursuant to
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`Federal Rule of Civil Procedure 26(a)(l) by January 17, 2020. If they have not already done so,
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`the parties are to review the Court' s Default Standard for Discovery, Including Discovery of
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`- I -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 1
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 2 of 15 PageID #: 694
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`Electronically Stored Information ("ESI") (which is posted at http://www.ded .uscourts.gov; see
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`Other Resources, Default Standards for Discovery, and is incorporated herein by reference). 1
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`2.
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`Joinder of Other Parties and Amendment of Pleadings. All motions to join other
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`parties, and to amend or supplement the pleadings, shall be filed on or before January 13, 2020.
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`3.
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`Application to Court for Protective Order. Should counsel find it will be
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`necessary to apply to the Court for a protective order specifying terms and conditions for the
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`disclosure of confidential information, counsel should confer and attempt to reach an agreement
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`on a proposed form of order and submit it to the Court within ten ( 10) days from the date of this
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`Order. Should counsel be unable to reach an agreement on a proposed form of order, counsel
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`must follow the provisions of Paragraph 8(g) below.
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`Any proposed protective order must include the following paragraph:
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`Other Proceedings. By entering this order and limiting the
`disclosure of information in this case, the Court does not intend to
`preclude another court from finding that information may be
`relevant and subject to disclosure in another case. Any person or
`party subject to this order who becomes subject to a motion to
`disclose another party's information designated "confidential" [the
`parties should list any other level of designation, such as "highly
`confidential," which may be provided for in the protective order]
`pursuant to this order shall promptly notify that party of the motion
`so that the party may have an opportunity to appear and be heard
`on whether that information should be disclosed .
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`4.
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`Papers Filed Under Seal.
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`In accordance with section G of the Administrative
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`Procedures Governing Filing and Service by Electronic Means, a redacted version of any sealed
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`document shall be filed electronically within seven (7) days of the filing of the sealed document.
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`Should any party intend to request to seal or redact all or any portion of a transcript of a
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`court proceeding (including a teleconference), such party should expressly note that intent at the
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`1 Attached as Exhibit A is a proposed schedule listing the events and proposed dates m
`chronological order.
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`- 2 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 2
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 3 of 15 PageID #: 695
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`start of the court proceeding. Should the party subsequently choose to make a request for sealing
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`or redaction, it must, promptly after the completion of the transcript, file with the Court a motion
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`for sealing/redaction, and include as attachments (1) a copy of the complete transcript
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`highlighted so the Court can easily identify and read the text proposed to be sealed/redacted, and
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`(2) a copy of the proposed redacted/sealed transcript. With their request, the party seeking
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`redactions must demonstrate why there is good cause for the redactions and why disclosure of
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`the redacted material would work a clearly defined and serious injury to the party seeking
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`redaction.
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`5.
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`Courtesy Copies. Other than with respect to "discovery matters," which are
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`governed by paragraph 8(g), and the final pretrial order, which is governed by paragraph 20, the
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`parties shall provide to the Court two (2) courtesy copies of all briefs and one (1) courtesy copy
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`of any other document filed in support of any briefs (i.e., appendices, exhibits, declarations,
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`affidavits etc.). This provision also applies to papers filed under seal.
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`6.
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`ADR Process. This matter is referred to a magistrate judge to explore the
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`possibility of alternative dispute resolution.
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`7.
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`Disclosures. Absent agreement among the parties, and approval of the Court:
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`a.
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`By January 17, 2020, Plaintiffs shall identify the accused product(s),
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`including accused methods and systems, and its damages model, as well as the asserted patent(s)
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`that the accused product(s) allegedly infringe(s). Plaintiff shall also produce the file history for
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`each asserted patent.
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`b.
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`By January 30, 2020, Defendants shall produce core technical documents
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`related to the accused product(s), sufficient to show how the accused product(s) work(s),
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`including but not limited to non-publicly available operation manuals, product literature,
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`- 3 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 3
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 4 of 15 PageID #: 696
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`schematics, and specifications. Defendants shall also produce sales figures for the accused
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`product(s).
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`c.
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`By February 21 , 2020, Plaintiffs shall produce an initial claim chart
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`relating each known accused product to the asserted claims each such product allegedly
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`infringes.
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`d.
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`By March 18, 2020, Defendants shall produce its
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`initial
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`invalidity
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`contentions for each asserted claim, as well as the known related invalidating references.
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`e.
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`By November 12, 2020, Plaintiffs shall provide final
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`infringement
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`contentions.
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`contentions.
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`f.
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`By December 17, 2020, Defendants shall provide final
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`invalidity
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`8.
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`Discovery. Unless otherwise ordered by the Court, the limitations on discovery
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`set forth in Local Rule 26.1 shall be strictly observed.
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`a.
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`Discovery Cut Off. All fact discovery in this case shall be initiated so that
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`it will be completed on or before March 2, 2021.
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`b.
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`Document Production. Document production shall be substantially
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`complete by January 5, 2021.
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`C.
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`Requests for Admission. A maximum of 50 requests for admission are
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`permitted for each side.
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`d.
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`Interrogatories.
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`i.
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`A maximum of 25
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`interrogatories,
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`including
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`contention
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`interrogatories, are permitted for each side.
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`11.
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`The Court encourages
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`the parties
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`to serve and respond
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`to
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`contention interrogatories early in the case.
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`In the absence of
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`- 4 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 4
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 5 of 15 PageID #: 697
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`agreement among the parties, contention interrogatories, if filed,
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`shall first be addressed by the party with the burden of proof. The
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`adequacy of all interrogatory answers shall be judged by the level
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`of detail each party provides; i.e., the more detail a party provides,
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`the more detail a party shall receive.
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`e.
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`Depositions.
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`i.
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`Limitation on Hours for Deposition Discovery. The parties agree
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`that the limitations regarding the number of fact depositions
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`imposed by the Federal Rules of Civil Procedure shall apply in this
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`case. Plaintiffs shall be entitled to take ten (10) fact depositions
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`and Defendants
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`shall be entitled
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`to
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`take
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`ten
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`( 10)
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`fact
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`depositions . Each deposition shall be limited to a single day of no
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`more than seven (7) hours, in accordance with Rule 30(d)(l) of the
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`Federal Rules of Civil Procedure unless otherwise ordered by the
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`Court. An exception shall be made for witnesses requiring an
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`interpreter, in which case, the deposition shall be limited to no
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`more than ten and one half (10.5) hours. Additionally, each
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`deposition on a party under Rule 30(b)(6) may proceed for up to
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`seven (7) hours (without an interpreter) or ten and one half (10.5)
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`hours (if an interpreter is required) per witness, and all depositions
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`taken under Rule 30(b)(6) shall collectively count towards only one
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`(1) deposition of the ten (10) fact deposition limit per side
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`regardless of the number of witnesses deposed under Rule 30(b)(6).
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`- 5 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 5
`
`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 6 of 15 PageID #: 698
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`II.
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`Location of Depositions. For witnesses located in China, witnesses
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`will be made available in Hong Kong or another mutually agreed
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`upon location convenient to the witnesses. The Parties will make
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`reasonable efforts to coordinate the scheduling of any foreign
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`depositions to avoid the need for multiple trips. ln addition to the
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`above, for any witness, whether located within the United States or
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`abroad, the deposition will be conducted at a location convenient to
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`the witness as reasonably determined by the producing party.
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`Notwithstanding the foregoing, the Parties agree that all expert
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`depositions shall take place in the United States.
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`f.
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`Disclosure of Expert Testimony.
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`1.
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`Expert Reports. For the party who has the initial burden of proof
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`on the subject matter, the initial Federal Rule 26(a)(2) disclosure of
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`expert testimony is due on or before April 14, 2021. The
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`supplemental disclosure to contradict or rebut evidence on the same
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`matter identified by another party is due on or before May 11 ,
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`2021. Reply expert reports from the party with the initial burden of
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`proof are due on or before May 28, 2021. Expert discovery shall be
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`completed by June 23 , 2021. No other expert reports will be
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`permitted without either the consent of all parties or leave of the
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`Court. Along with the submissions of the expert reports, the parties
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`shall advise of the dates and times of their experts' availability for
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`deposition.
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`- 6 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 6
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 7 of 15 PageID #: 699
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`11.
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`Expert Report Supplementation. The parties agree they will not
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`permit expert declarations to be filed in connection with motions
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`briefing (including case-dispositive motions) after the close of fact
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`and expert discovery without the other parties' agreement or leave
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`of the Court.
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`iii.
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`Objections to Expert Testimony. To the extent any objection to
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`expert testimony is made pursuant to the principles announced in
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`Daubert v. Merrell Dow Pharm. , Inc., 509 U.S. 579 (1993), as
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`incorporated in Federal Rule of Evidence 702, it shall be made by
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`motion no later than the deadline for dispositive motions set forth
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`herein, unless otherwise ordered by the Court. Briefing on such
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`motions is subject to the page limits set out in connection with
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`briefing of case dispositive motions.
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`g.
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`Discovery Matters and Disputes Relating to Protective Orders.
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`i.
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`Any discovery motion filed without first complying with the
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`following procedures will be denied without prejudice to renew
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`pursuant to these procedures.
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`11.
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`Should counsel find, after good faith efforts -
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`including verbal
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`communication among Delaware and Lead Counsel for all parties
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`to the dispute -
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`that they are unable to resolve a discovery matter
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`or a dispute relating to a protective order, the parties involved in the
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`discovery matter or protective order dispute shall submit a joint
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`letter in substantially the following form:
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`Dear Judge Stark:
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`- 7 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 7
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 8 of 15 PageID #: 700
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`The parties in the above-referenced
`matter write to request the scheduling of a
`discovery teleconference.
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`The following attorneys, including
`at least one Delaware Counsel and at least
`one Lead Counsel per party, participated in
`a verbal meet-and-confer (in person and/or
`by telephone) on the following date(s):
`
`Delaware Counsel: - - - - - - - -
`Lead Counsel : - - - - - - - - - -
`The disputes
`requmng
`judicial
`attention are listed below:
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`[provide here a non-argumentative list of
`disputes requiring judicial attention]
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`iii.
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`On a date to be set by separate order, generally not less than forty(cid:173)
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`eight ( 48) hours prior to the conference, the party seeking relief
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`shall file with the Court a letter, not to exceed three (3) pages,
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`outlining the issues in dispute and its position on those issues. On a
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`date to be set by separate order, but generally not less than twenty(cid:173)
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`four (24) hours prior to the conference, any party opposing the
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`application for relief may file a letter, not to exceed three (3) pages,
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`outlining that party' s reasons for its opposition.
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`1v.
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`Each party shall submit two (2) courtesy copies of its discovery
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`letter and any attachments.
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`v.
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`Should the Court find further briefing necessary upon conclusion of
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`the telephone conference, the Court will order it. Alternatively, the
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`- 8 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 8
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 9 of 15 PageID #: 701
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`Court may choose to resolve the dispute prior to the telephone
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`conference and will, in that event, cancel the conference.
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`9.
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`Motions to Amend.
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`a.
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`Any motion to amend (including a motion for leave to amend) a pleading
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`shall NOT be accompanied by an opening brief but shall, instead, be accompanied by a letter, not
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`to exceed three (3) pages, describing the basis for the requested relief, and shall attach the
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`proposed amended pleading as well as a "blackline" comparison to the prior pleading.
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`b.
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`Within seven (7) days after the filing of a motion in compliance with this
`
`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
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`pages.
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`c.
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`Within three (3) days thereafter, the moving party may file a reply letter,
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`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
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`teleconference to address the motion to amend.
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`10. Motions to Strike.
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`a.
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`Any motion to strike any pleading or other document shall NOT be
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`accompanied by an opening brief but shall, instead, be accompanied by a letter, not to exceed
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`three (3) pages, describing the basis for the requested relief, and shall attach the document to be
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`stricken.
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`b.
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`Within seven (7) days after the filing of a motion in compliance with this
`
`Order, any party opposing such a motion shall file a responsive letter, not to exceed five (5)
`
`pages.
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`c.
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`Within three (3) days thereafter, the moving party may file a reply letter,
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`not to exceed two (2) pages, and, by this same date, the parties shall file a letter requesting a
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`teleconference to address the motion to strike.
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`- 9 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 9
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`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 10 of 15 PageID #: 702
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`11.
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`Tutorial Describing the Technology and Matters in Issue. Unless otherwise
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`ordered by the Court, the parties shall provide the Court, no later than the date on which their
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`opening claim construction briefs are due, a tutorial on the technology at issue. In that regard,
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`the parties may separately or jointly submit a DVD of not more than thirty (30) minutes. The
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`tutorial should focus on the technology in issue and should not be used for argument. The parties
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`may choose to file their tutorial(s) under seal, subject to any protective order in effect. Each
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`party may comment, in writing (in no more than five (5) pages) on the opposing party' s tutorial.
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`Any such comment shall be filed no later than the date on which the answering claim
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`construction briefs are due. As to the format selected, the parties should confirm the Court' s
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`technical abilities to access the information contained in the tutorial (currently best are "mpeg"
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`or "quick:time").
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`12.
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`Claim Construction Issue Identification. On April 22, 2020, the parties shall
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`exchange a list of those claim term(s)/phrase(s) that they believe need construction and their
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`proposed claim construction of those term(s)/phrase(s). This document will not be filed with the
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`Court. Subsequent to exchanging that list, the parties will meet and confer to prepare a Joint
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`Claim Construction Chart to be submitted on May 27, 2020. The parties ' Joint Claim
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`Construction Chart should identify for the Court the term(s)/phrase(s) of the claim(s) in issue,
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`and should include each party' s proposed construction of the disputed claim language with
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`citation(s) only to the intrinsic evidence in support of their respective proposed constructions. A
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`copy of the patent(s) in issue as well as those portions of the intrinsic record relied upon shall be
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`submitted with this Joint Claim Construction Chart. In this joint submission, the parties shall not
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`provide argument.
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`13.
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`Claim Construction Briefing. The parties shall contemporaneously submit initial
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`briefs on claim construction issues on June 22, 2020. The parties ' answering/responsive briefs
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`- 10 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 10
`
`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 11 of 15 PageID #: 703
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`shall be contemporaneously submitted on July 10, 2020. No reply briefs or supplemental papers
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`on claim construction shall be submitted without leave of the Court. Local Rule 7.1.3(4) shall
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`control the page limitations for initial (opening) and responsive (answering) briefs.
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`Hearing on Claim Construction. Beginning at ~: 00 on 1~;~ _R_, 2020, the
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`14.
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`Court will hear argument on claim construction. The parties shall notify the Court, by joint letter
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`submission, no later than the date on which their answering claim construction briefs are due: (i)
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`whether they request leave to present testimony at the hearing; and (ii) the amount of time they
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`are requesting be allocated to them for the hearing.
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`Provided that the parties comply with all portions of this Scheduling Order, and any other
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`orders of the Court, the parties should anticipate that the Court will issue its claim construction
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`order within sixty (60) days of the conclusion of the claim construction hearing. If the Court is
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`unable to meet this goal, it will advise the parties no later than sixty (60) days after the
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`conclusion of the claim construction hearing.
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`15 .
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`Interim Status Report. On August 5, 2020, counsel shall submit a joint letter to
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`the Court with an interim report on the nature of the matters in issue and the progress of
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`discovery to date. Thereafter, if the Court deems it necessary, it will schedule a status
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`conference.
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`16.
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`Supplementation. Absent agreement among the parties, and approval of the
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`Court, no later than November 12, 2020, the Plaintiffs must finally supplement, inter alia, the
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`identification of all accused products, and no later than December 17, 2020, the Defendants must
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`finally supplement, inter alia, the identification of all invalidity references.
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`17.
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`Case Dispositive Motions. All case dispositive motions, an opening brief, and
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`affidavits, if any, in support of the motion shall be served and filed on or before August 16, 2021.
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`Responsive briefs shall be served and filed on September 20, 2021. Reply briefs shall be served
`
`- 11 -
`
`Chervon (HK) Limited
`Exhibit 2002 - Page 11
`
`

`

`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 12 of 15 PageID #: 704
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`and filed on or before October 6, 2021 . Briefing will be presented pursuant to the Court' s Local
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`Rules, as modified by this Order.
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`a.
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`No early motions without leave. No case dispositive motion under Rule 56
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`may be filed more than ten ( 10) days before the above date without leave of the Court.
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`b.
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`Page limits combined with Daubert motion page limits. Each party is
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`permitted to file as many case dispositive motions as desired ; provided, however, that each SIDE
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`will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40
`
`pages for all answering briefs, and a combined total of 20 pages for all reply briefs regardless of
`
`the number of case dispositive motions that are filed. In the event that a party files, in addition to
`
`a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an
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`expert' s testimony, the total amount of pages permitted for all case dispositive and Daubert
`
`motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs,
`
`and 25 pages for all reply briefs for each SIDE. 2
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`c.
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`Hearing. The Court will hear argument on all pending case dispositive and
`
`Daubert motions on November i
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`, 2021 beginning at j ·. oO . Subject to further order of the
`
`Court, each side will be allocated a total of forty-five ( 45) minutes to present its argument on all
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`pending motions.
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`18.
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`Applications by Motion.
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`Except as otherwise specified herein, any application
`
`to the Court shall be by written motion filed with the Clerk. Any non-dispositive motion should
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`contain the statement required by Local Rule 7 .1.1.
`
`2 The parties must work together to ensure that the Court receives no more than a total of 250
`pages (i.e., 50 + 50 + 25 regarding one side 's motions, and 50 + 50 + 25 regarding the other
`side's motions) of briefing on all case dispositive motions and Daubert motions that are covered
`by this scheduling order and any other scheduling order entered in any related case that is
`proceeding on a consolidated or coordinated pretrial schedule.
`
`- 12 -
`
`Chervon (HK) Limited
`Exhibit 2002 - Page 12
`
`

`

`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 13 of 15 PageID #: 705
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`Pretrial Conference. On February "X,, 2022, the Court will hold a pretrial
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`~s
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`19.
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`conference in Court with counsel beginning at 9 a.m . Unless otherwise ordered by the Court, the
`
`parties should assume that filing the pretrial order satisfies the pretrial disclosure requirement of
`
`Federal Rule of Civil Procedure 26(a)(3). The parties shall file with the Court the joint proposed
`
`final pretrial order with the information required by the form of Revised Final Pretrial Order -
`Ft..L .
`Patent, which can be found on the Court' s website (www.ded.uscourts.gov), on or before JaRttm-y
`
`14, 2022. Unless otherwise ordered by the Court, the parties shall comply with the timeframes
`
`set forth in Local Rule 16.3( d)(l )-(3) for the preparation of the joint proposed final pretrial order.
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`The parties shall provide the Court two (2) courtesy copies of the joint proposed final
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`pretrial order and all attachments.
`
`As noted in the Revised Final Pretrial Order -
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`Patent, the parties shall include in their
`
`joint proposed final pretrial order, among other things:
`
`a.
`
`a request for a specific number of hours for their trial presentations, as
`
`well as a requested number of days, based on the assumption that in a typical jury trial day (in
`
`which there is not jury selection, jury instruction, or deliberations), there will be 5 ½ to 6 ½
`
`hours of trial time, and in a typical bench trial day there will be 6 to 7 hours of trial time;
`
`b.
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`their position as to whether the Court should allow objections to efforts to
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`impeach a witness with prior testimony. including objections based on lack of completeness
`
`and/or lack of inconsistency;
`
`c.
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`their position as to whether the Court should rule at trial on objections to
`
`expert testimony as beyond the scope of prior expert disclosures, taking time from the parties'
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`trial presentation to argue and decide such objections, or defer ruling on all such objections
`
`un less renewed in writing following trial, subject to the proviso that a party prevailing on such a
`
`- 13 -
`
`Chervon (HK) Limited
`Exhibit 2002 - Page 13
`
`

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`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 14 of 15 PageID #: 706
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`post-trial objection will be entitled to have all of its costs associated with a new trial paid for by
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`the party that elicited the improper expert testimony at the earlier trial ; and
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`d.
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`their position as to how to make motions for judgment as a matter of law,
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`whether it be immediately at the appropriate point during trial or at a subsequent break, whether
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`the jury should be in or out of the courtroom, and whether such motions may be supplemented in
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`writing.
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`20. Motions in Limine. Motions in limine shall not be separately filed . All in limine
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`requests and responses thereto shall be set forth in the proposed pretrial order. Each SIDE shall
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`be limited to three (3) in limine requests, unless otherwise permitted by the Court. The in limine
`
`request and any response shall contain the authorities relied upon ; each in limine request may be
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`supported by a maximum of three (3) pages of argument and may be opposed by a maximum of
`
`three (3) pages of argument, and the side making the in limine request may add a maximum of
`
`one (1) additional page in reply in support of its request. If more than one party is supporting or
`
`opposing an in limine request, such support or opposition shall be combined in a single three (3)
`
`page submission (and, if the moving party, a single one ( 1) page reply), unless otherwise ordered
`
`by the Court. No separate briefing shall be submitted on in limine requests, unless otherwise
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`permitted by the Court.
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`21.
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`Jury Instructions, Voir Dire, and Special Verdict Forms. Where a case is to be
`
`tried to a jury, pursuant to Local Rules 47 and 51 the parties should file (i) proposed voir dire,
`
`(ii) preliminary jury instructions, (iii) final jury instructions, and (iv) special verdict forms three
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`(3) business days before the final pretrial conference. This submission shall be accompanied by
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`a courtesy copy containing electronic files of these documents, in WordPerfect or Microsoft
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`Word format, which may be submitted by e-mail to Judge Stark's staff.
`
`- 14 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 14
`
`

`

`Case 1:19-cv-01293-LPS Document 37 Filed 03/11/20 Page 15 of 15 PageID #: 707
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`22.
`Trial. This matter is scheduled for a five (5) day jury trial beginning at 9:30 a.m.
`on March l_, 2022, with the subsequent trial days beginning at 9:00 a.m. Until the case is
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`submitted to the jury for deliberations, the jury will be excused each day at 4:30 p.m. The trial
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`will be timed, as counsel will be allocated a total number of hours in which to present their
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`respective cases.
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`23 .
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`Judgment on Verdict and Post-Trial Status Report. Within seven (7) days after a
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`jury returns a verdict in any portion of a jury trial, the parties shall jointly submit a form of order
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`to enter judgment on the verdict. At the same time, the parties shall submit a joint status report,
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`indicating among other things how the case should proceed and listing any post-trial motions
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`each party intends to file .
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`24.
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`Post-Trial Motions. Unless otherwise ordered by the Court, all SIDES are limited
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`to a maximum of 20 pages of opening briefs, 20 pages of answering briefs, and IO pages of reply
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`briefs relating to any post-trial motions filed by that side, no matter how many such motions are
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`filed .
`
`UNITED S
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`- 15 -
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`Chervon (HK) Limited
`Exhibit 2002 - Page 15
`
`