Icon-IP Pty Ltd. v. Specialized Bicycle Components, Inc.

Filing 76

STIPULATION AND ORDER re 75 STIPULATION WITH PROPOSED ORDER to Continue Pretrial Deadlines Pursuant to Civil L.R. 6-2 filed by Icon-IP Pty Ltd. Signed by Judge Jon S. Tigar on May 6, 2014. (wsn, COURT STAFF) (Filed on 5/6/2014)

MARTIN L. FINEMAN (Bar No. 104413)
DAVIS WRIGHT TREMAINE LLP
One Embarcadero Center, Suite 600
San Francisco, California 94111-3611
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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RAYMOND P. NIRO
FREDERICK C. LANEY (admitted pro hac vice)
ASHLEY E. LaVALLEY (admitted pro hac vice)
NIRO, HALLER & NIRO
181 W. Madison, Suite 4600
Chicago, Illinois 60602
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Plaintiff ICON-IP PTY LTD.

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DARRELL L. OLSON (Bar No. 77633)
[e-mail]
EDWARD A. SCHLATTER (Bar No.
120177)
[e-mail]
BENJAMIN EVERTON
[e-mail]
Knobbe, Martens, Olson & Bear, LLP
2040 Main Street, Suite 1400
Irvine, CA 92614
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant SPECIALIZED
BICYCLE COMPONENTS, INC.

IN THE UNTIED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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ICON-IP PTY LTD.,
Plaintiff,

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v.

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SPECIALIZED BICYCLE.
COMPONENTS, INC.,

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Defendant.

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12-cv-03844-JST

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE PRETRIAL
DEADLINES PURSUANT TO CIVIL
L.R. 6-2

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STIPULATION AND PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2
CASE NO. 12-CV-03844-JST

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Pursuant to Civil Local Rule 6-2, Plaintiff Icon-IP Pty Ltd. (“Icon”) and Defendant

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Specialized Bicycle Components, Inc. (“Specialized”), by and through their respective counsel of

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record, hereby stipulate and request that the Court enter an Order extending certain pretrial deadlines

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by thirty (30) days as set forth below. In support of this request, the parties state as follows:
WHEREAS, on April 19, 2013, the Court issued an Order setting the pretrial deadlines (Dkt.

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No. 26);
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WHEREAS, counsel for Icon will be at trial beginning May 6, 2014 in the Central District of
California, which is expected to last two weeks;
WHEREAS, in light of trial, Icon believes it requires additional time to complete fact
discovery prior to the currently schedule deadline;
WHEREAS, Defendant has agreed to a thirty-day extension of certain currently scheduled
deadlines as set forth below.

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WHEREAS, the parties have previously stipulated to extend the deadline for the parties to

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hold an ADR session from January 30, 2013 to March 27, 2013 and again stipulated to extend the

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deadline for the parties to hold an ADR session from March 27, 2013 to April 30, 2013;

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WHEREAS, this requested extension will not affect any deadlines for any matter required to
be filed or lodged with Court, including the deadlines for the parties to file dispositive motions.

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WHEREAS, this stipulation is not entered into for the purpose of delay;
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NOW THEREFORE, in consideration of the foregoing, the parties by and through their
undersigned counsel, hereby stipulate and request that the Court enter an Order continuing certain
deadlines as follows:

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Event
Advice of Counsel disclosures due
(Patent L.R. 3-7)
Close of Fact Discovery
Designation of Expert Witnesses and
Exchange of Initial Expert Reports
for which party bears burden

Current Dates
June 5, 2014

Proposed Dates
July 7, 2014

August 15, 2014
September 19, 2014

September 19, 2014
October 17, 2014

STIPULATION AND PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2
CASE NO. 12-CV-03844-JST

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Designation of Rebuttal Experts and
Exchange of Rebuttal Expert
Reports
Close of Expert Discovery
Deadline to File Dispositive Motions
and any motion to limit or exclude
Expert Testimony
Pretrial Conference

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Trial

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October 17, 2014

November 14, 2014

November 14, 2014
January 23, 2015

December 19, 2014
January 23, 2015

At the Court’s
Convenience
At the Court’s
Convenience

At the Court’s
Convenience
At the Court’s
Convenience

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IT IS SO STIPULATED.

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Dated: May 5, 2014

By:
/s/ Ashley E. LaValley
Raymond P. Niro
Frederick C. Laney
Ashley E. Lavalley
NIRO, HALLER & NIRO
Attorneys for ICON-IP PTY, LTD.

Dated: May 5, 2014

By:
/s/ Darrell L. Olson
Darrell L. Olson
Edward A. Schlatter
Benjamin J. Everton
KNOBBE, MARTENS, OLSON & BEAR, LLP
Attorneys for SPECIALIZED BICYCLE
COMPONENTS, INC.

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STIPULATION AND PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2
CASE NO. 12-CV-03844-JST

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, the Court continues the fact and expert discovery

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deadlines by thirty (30) days as follows:

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December 19, 2014
January 23, 2015

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Dated:
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nS
J u d ge J o

ER

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The Honorable Jon S. Tigar
UNITED STATES DISTRICT JUDGE

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DERED

O OR
IT IS S

NO

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May 6, 2014

By:

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U
O

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S DISTRICT
TE
C
TA
PURSUANT TO STIPULATION, IT IS SO ORDERED.

. Ti ga r

R NIA

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At the Court’s Convenience
At the Court’s Convenience

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November 14, 2014

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Event
Advice of Counsel disclosures due (Patent L.R. 3-7)
Close of Fact Discovery
Designation of Expert Witnesses and Exchange of Initial
Expert Reports for which party bears burden
Designation of Rebuttal Experts and Exchange of Rebuttal
Expert Reports
Close of Expert Discovery
Deadline to File Dispositive Motions and any motion to limit
or exclude Expert Testimony
Pretrial Conference
Trial

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Dates
July 7, 2014
September 19, 2014
October 17, 2014

UNIT
ED

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N

F
D IS T IC T O
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C

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STIPULATION AND PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2
CASE NO. 12-CV-03844-JST

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FILER’S ATTESTATION

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Pursuant to Civil Local Rule 5-1(i) regarding signatures, I, Ashley E. LaValley, attest that

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concurrence in the filing of this document has been obtained from each of the other signatories. I

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declare under penalty of perjury under the laws of the United States of America that the foregoing is

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true and correct.

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Dated:

May 5, 2014

By:

/s/ Ashley E. LaValley
Ashley E. LaValley
NIRO, HALLER, & NIRO
Attorney for Plaintiff, ICON-IP PTY LTD.

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STIPULATION AND PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2
CASE NO. 12-CV-03844-JST

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