Illinois Union Insurance Company v. Intuitive Surgical, Inc.

Filing 200

STIPULATION AND ORDER re 199 STIPULATION WITH PROPOSED ORDER TO EXTEND EXPERT DEADLINES BY 10 DAYS filed by Illinois Union Insurance Company. Expert Reports Due December 23, 2016. Rebuttal Expert Reports Due January 27, 2017. Close Of Expert Discovery February 10, 2017. Signed by Judge Jon S. Tigar on December 8, 2016. (wsn, COURT STAFF) (Filed on 12/8/2016)

1 Thomas M. Jones (Pro Hac Vice)
Charles E. Wheeler, SBN 82915
2 Sean V. Walton (Pro Hac Vice)
COZEN O'CONNOR
3 501 West Broadway, Suite 1610
San Diego, CA 92101
4 Telephone: [phone]
Facsimile: 619.234.7831
5 [e-mail]
[e-mail]
6 [e-mail]
7 Attorneys for Plaintiff/Defendant
ILLINOIS UNION INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION

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ILLINOIS UNION INSURANCE
12 COMPANY, an Illinois corporation,
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Plaintiff,
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v.
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INTUITIVE SURGICAL, INC., a Delaware )
corporation,
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Defendant.
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Case No. 3:13-cv-04863-JST
Case No. 3:15-cv-04834-JST
Hon. Jon S. Tigar
JOINT STIPULATION TO
EXTEND EXPERT DEADLINES
BY 10 DAYS; AND
[PROPOSED] ORDER.
Trial Date: June 19, 2017

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20 And Related Actions.
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Illinois Union Insurance Company (“Illinois Union”) and Intuitive Surgical,

22 Inc. (“Intuitive”) jointly stipulate, pursuant to Local Rules 6-1(b), 6-2, and 7-12, to
23 extend—by 10 days—the expert deadlines in the consolidated actions, Case No. 3:1324 cv-04863-JST and Case No. 3:15-cv-04834-JST, if it pleases the Court.
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WHEREAS, on July 26, 2016, the parties submitted a Joint Stipulation to Enter
26 Scheduling Order, which was approved and entered by the Court on July 27, 2016
27 (ECF No. 186 in Case No. 3:13-cv-04863-JST).
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JOINT STIPULATION TO EXTEND
EXPERT DEADLINES BY 10 DAYS

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CASE NO. 3:13-CV-04863-JST
CASE NO. 3:15-CV-04834-JST

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WHEREAS, the Scheduling Order provided for the following expert report and

2 discovery deadlines:
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Expert Reports Due – December 13, 2016

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Rebuttal Expert Reports Due – January 17, 2017

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Close Of Expert Discovery – January 31, 2017

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WHEREAS, the parties, through their counsel, have agreed to a 10-day

7 extension of the above expert deadlines.
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NOW THEREFORE, the parties, through their undersigned counsel, hereby

9 respectfully stipulate and request that the Court extend the above expert deadlines by
10 10 days, as follows:
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Expert Reports Due – December 13, 2016 – December 23, 2016

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Rebuttal Expert Reports Due – January 17, 2017 – January 27, 2017

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Close Of Expert Discovery – January 31, 2017 – February 10, 2017

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The parties further stipulate that this change in the expert deadlines will not

15 change or affect any of the other dates in the Scheduling Order entered on July 27,
16 2016.
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JOINT STIPULATION TO EXTEND
EXPERT DEADLINES BY 10 DAYS

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CASE NO. 3:13-CV-04863-JST
CASE NO. 3:15-CV-04834-JST

1 DATED: December 8, 2016

COZEN O’CONNOR

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By: /s/ Charles E. Wheeler
Attorneys for Plaintiff/Defendant
ILLINOIS UNION INSURANCE
COMPANY

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SKADDEN, ARPS, SLATE,
MEAGHER, & FLOM LLP

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By: /s/ James P. Schaefer
Attorneys for Defendant/Plaintiff
INTUITIVE SURGICAL, INC.

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Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the

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16 filing of this document has been obtained from the signatories above.
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/s/ Charles E. Wheeler

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JOINT STIPULATION TO EXTEND
EXPERT DEADLINES BY 10 DAYS

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CASE NO. 3:13-CV-04863-JST
CASE NO. 3:15-CV-04834-JST

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[PROPOSED] ORDER
PURSUANT TO THE FORGEOING STIPULATION OF THE PARTIES,

3 IT IS ORDERED THAT:
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The Court enters the following modifications to the case schedule for the

5 consolidated actions, Case No. 3:13-cv-04863-JST and Case No. 3:15-cv-04834-JST:
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Expert Reports Due – December 13, 2016 – December 23, 2016

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Rebuttal Expert Reports Due – January 17, 2017 – January 27, 2017

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Close Of Expert Discovery – January 31, 2017 – February 10, 2017

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10 DATED: December 8, 2016
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____________________________
The Honorable Jon S. Tigar
United States District Court Judge

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JOINT STIPULATION TO EXTEND
EXPERT DEADLINES BY 10 DAYS

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CASE NO. 3:13-CV-04863-JST
CASE NO. 3:15-CV-04834-JST