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

Filing 97

STIPULATION AND ORDER re 96 STIPULATION WITH PROPOSED ORDER TO CONTINUE PRETRIAL DEADLINES PURSUANT TO CIVIL L.R. 6-2 filed by Specialized Bicycle Components, Inc. Dispositive Motions due by 1/23/2015. Pretrial Conference Statemen t due by 4/21/2015. Final Pretrial Conference set for 5/1/2015 at 2:00 PM in Courtroom 2, 4th Floor, Oakland. Jury Trial set for 5/26/2015 at 8:30 AM in Courtroom 9, 19th Floor, San Francisco before Hon. Jon S. Tigar. Signed by Judge Jon S. Tigar on August 21, 2014. (wsn, COURT STAFF) (Filed on 8/21/2014)

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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]
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)
BENJAMIN J. EVERTON (Bar No.
259214)
Knobbe, Martens, Olson & Bear, LLP
2040 Main Street, Suite 1400
Irvine, CA 92614
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant SPECIALIZED
BICYCLE COMPONENTS, INC.

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

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ICON-IP PTY, LTD.,
Plaintiff,
v.

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SPECIALIZED BICYCLE
COMPONENTS, INC.,

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Defendant.

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) Case No. CV-12-3844 JST
)
)
)
) STIPULATION AND [PROPOSED]
) ORDER TO CONTINUE PRETRIAL
) DEADLINES PURSUANT TO CIVIL
) L.R. 6-2
)
)
) Hon. Jon S. Tigar
)
)
)

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STIPULATION AND PROPOSED ORDER CONTINUE PRETRIAL DEADLINES
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, the parties are actively pursuing fact discovery and are still working to resolve
issues related to discovery requests and the scheduling of depositions;
WHEREAS, the parties believe the proposed extension of the deadlines will allow the parties
to complete discovery;

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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, the parties have previously stipulated to extend pretrial deadlines (Dkt. No. 75);

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WHEREAS, this requested extension will not affect any deadlines for any matter required to

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be filed or lodged with the Court, including deadlines for the parties to file dispositive motions.
WHEREAS, the parties do not believe the extension sought hereby will prejudice either party

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or result in undue delay;
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NOW THEREFORE, in consideration of the foregoing, the parties by and through their
undersigned counsel, hereby stipulated and request that the Court enter an Order continuing certain
deadlines as follows:
Event
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

Current Dates
September 19, 2014

Proposed Dates
October 24, 2014

October 17, 2014

November 21, 2014

November 14, 2014

December 19, 2014

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

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Close of Expert Discovery
Deadline to File Dispositive
Motions
Pretrial Conference
Trial

December 19, 2014

January 19, 2015

January 23, 2015

January 23, 2015

At Court’s Convenience
At Court’s Convenience

At Court’s Convenience
At Court’s Convenience

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IT IS SO STIPULATED.

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Dated: August 20, 2014

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

Dated: August 20, 2014

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

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

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[PROPOSED] ORDER

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deadlines as follows:
Dates
October 24, 2014
November 21, 2014

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December 19, 2014
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S DISTRICT
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: August 21, 2014

ERED

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By:
SO OR
IT IS Jon S. DIFIED
The Honorable MO Tigar
AS
UNITED STATES DISTRICT JUDGE

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UNIT
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January 19, 2015
January 23, 2015
April 21, 2015
May 1, 2015 at 2:00 p.m.
May 26, 2015 at 8:30 a.m.

Event
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
Pretrial Conference Statement
Pretrial Conference
Jury Trial

R NIA

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Pursuant to the parties’ stipulation, the Court continues the fact and expert discovery

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N

D IS T IC T
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OF

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STIPULATION AND PROPOSED ORDER CONTINUE PRETRIAL DEADLINES
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, Benjamin J. Everton, 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: August 20, 2014

By:

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/s/Benjamin J. Everton
Benjamin J. Everton
KNOBBE, MARTENS, OLSON & BEAR, LLP
Attorneys for Defendant SPECIALIZED
BICYCLE COMPONENTS, INC.

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18694374

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18696655
082014

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

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