Finjan, Inc. v. Proofpoint, Inc. et al

Filing 205

ORDER by Judge Haywood S. Gilliam, Jr. Granting 204 Stipulation Extending Time for Expert Discovery. (ndrS, COURT STAFF) (Filed on 11/2/2015)

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PAUL J. ANDRE (State Bar No. 196585)
[e-mail]
LISA KOBIALKA (State Bar No. 191404)
[e-mail]
JAMES HANNAH (State Bar No. 237978)
[e-mail]
KRAMER LEVIN NAFTALIS
& FRANKEL LLP
990 Marsh Road
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]

JENNIFER A KASH (Bar No. 203679)
[e-mail]
SEAN PAK (Bar No. 219032)
[e-mail]
IMAN LORDGOOEI (Bar No. 251320)
[e-mail]
SAM STAKE (Bar No. 257916)
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111-4788
Telephone: [phone]
Facsimile: [phone]

Counsel for Plaintiff
FINJAN, INC.

Counsel for Defendants
PROOFPOINT, INC. and ARMORIZE
TECHNOLOGIES, INC.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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FINJAN, INC.,

Case No.: 13-CV-05808-HSG

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Plaintiff,

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v.
PROOFPOINT, INC. and ARMORIZE
TECHNOLOGIES, INC.,

STIPULATION AND ORDER
EXTENDING TIME FOR EXPERT
DISCOVERY
Trial Date:

March 7, 2016

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Defendants.

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__________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING
Case No.: 13-CV-05808-HSG
TIME FOR EXPERT DISCOVERY

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Pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12, Plaintiff Finjan, Inc. and Defendants

2 Proofpoint, Inc. and Armorize Technologies, Inc. (collectively, “the Parties”), by and through their
3 respective counsel, have met and conferred in an effort to agree upon a modified schedule for expert
4 discovery and have stipulated as follows:
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WHEREAS, the opening and rebuttal expert reports in this matter were scheduled to be

6 exchanged respectively on October 7, 2015 and October 28, 2015;
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WHEREAS, the completion of the expert discovery in this matter was scheduled on November

8 6, 2015;
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WHEREAS, the Parties stipulated to extend the dates for the exchange of opening expert

10 reports, rebuttal expert reports and the completion of expert discovery;
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WHEREAS, such extension was necessary to accommodate scheduling issues of the various

12 experts in this matter such as teaching schedules or (in one case) medical issues;
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WHEREAS, the Parties stipulated to extend the deadline for exchanging opening expert reports

14 to October 14, 2015 and opening expert reports were served on that date;
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WHEREAS, the Parties stipulated to extend the deadline for exchanging rebuttal expert reports

16 to November 4, 2015;
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WHEREAS, the Parties have stipulated that expert discovery will be extended to November 13,

18 2015, and damages expert discovery to November 20, 2015;
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NOW THEREFORE, the Parties hereby stipulate to and request (1) an extension of the

20 deadline to exchange opening expert reports from October 7, 2015 to October 14, 2015, (2) an
21 extension of the deadline to exchange rebuttal expert reports from October 28, 2014 to November 4,
22 2015, and (3) an extension of the completion of expert discovery from November 6, 2015 to November
23 13, 2015 for technical expert discovery and November 20, 2015 for damages expert discovery.
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IT IS SO STIPULATED.

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__________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING
Case No.: 13-CV-05808-HSG
TIME FOR CERTAIN DISCOVERY

Respectfully submitted,

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2 Dated: October 30, 2015
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By: /s/ James Hannah_____________
Paul J. Andre (SBN 196585)
Lisa Kobialka (SBN 191404)
James Hannah (SBN 237978)
KRAMER LEVIN NAFTALIS
& FRANKEL LLP
990 Marsh Road
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiff
FINJAN, INC.

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Respectfully submitted,

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13 Dated: October 30, 2015
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By: /s/ Jennifer Kash__________
Jennifer A Kash (Bar No. 203679)
Sean Pak (Bar No. 219032)
Iman Lordgooei (Bar No. 251320)
Sam Stake (Bar No. 257916)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111-4788
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Counsel for Defendants
PROOFPOINT, INC. and ARMORIZE
TECHNOLOGIES, INC.

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__________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING
Case No.: 13-CV-05808-HSG
TIME FOR CERTAIN DISCOVERY

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ATTESTATION PURSUANT TO L.R. 5-1(I)
In accordance with Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

3 document has been obtained from any other signatory to this document.
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/s/ James Hannah
James Hannah

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__________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING
Case No.: 13-CV-05808-HSG
TIME FOR CERTAIN DISCOVERY

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ORDER

2 PURSUANT TO STIPULATION, IT IS SO ORDERED.
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(1) The deadline for opening expert reports is extended from October 7, 2015, to October 14,

4 2015;
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(2) The deadline for rebuttal expert reports is extended from October 28, 2014 to November 4,

6 2015; and
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(3) The close of expert discovery is extended from November 6, 2015, to November 13, 2015

8 for technical expert discovery and to November 20, 2015 for damages expert discovery.
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10 DATED: November 2, 2015
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___________________________
The Honorable Haywood S. Gilliam, Jr.
United States District Judge

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__________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING
Case No.: 13-CV-05808-HSG
TIME FOR CERTAIN DISCOVERY