In re Ricoh Company Ltd. Patent Litigation

Filing 650

STIPULATION AND ORDER Setting Certain Pre-Trial Schedule Dates re 648 Stipulation. Signed by Judge James Ware on 12/14/2009. (ecg, COURT STAFF) (Filed on 12/14/2009)

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KENNETH W. BROTHERS (Pro Hac Vice) [e-mail] GARY M. HOFFMAN (Pro Hac Vice) [e-mail] DICKSTEIN SHAPIRO, LLP 1825 Eye Street, N.W. Washington, D.C. 20006 Telephone: [phone] Facsimile: [phone] DANIEL J. BERGESON, SBN 105439 [e-mail] DONALD P. GAGLIARDI, SBN 138979 [e-mail] HWAY-LING HSU, SBN 196178 [e-mail] BERGESON, LLP 303 Almaden Boulevard, Suite 500 San Jose, CA 95110-2712 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff RICOH COMPANY, LTD.

RON E. SHULMAN, SBN 178263 [e-mail] TERRY KEARNEY, SBN 160054 [e-mail] RICHARD G. FRENKEL, SBN 204133 [e-mail] WILSON SONSINI GOODRICH & ROSATI 650 Page Mill Road Palo Alto, CA 94304 Telephone: [phone] Facsimile: [phone] Attorneys for Synopsys, Inc. and Aeroflex et al. Defendants

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

IN RE RICOH COMPANY, LTD. PATENT LITIGATION

Case No. 03-CV-02289 JW (HRL) JOINT STIPULATION AND [PROPOSED] ORDER SETTING CERTAIN PRE-TRIAL SCHEDULE DATES

STIPULATION AND [PROPOSED] ORDER SETTING CERTAIN PRE-TRIAL SCHEDULE DATES Case No. 03-CV-02289 JW (HRL)

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1.

Pursuant to this Court's Order of November 23, 2009, Plaintiff and Counter-

Defendant Ricoh Company, Ltd. ("Ricoh"), Declaratory Judgment Plaintiff Synopsys, Inc. ("Synopsys"), and Defendants Aeroflex, Inc., AMI Semiconductor, Inc., Matrox Electronics Systems, Ltd., Matrox Graphics, Inc., Matrox International Corp., Matrox Tech., Inc. and Aeroflex Colorado Springs, Inc. (the "Aeroflex et al. Defendants" or "Customer Defendants") (collectively "the Parties"), hereby jointly and collectively submit this Stipulation Setting Certain Pre-Trial Schedule Dates. PROPOSED SCHEDULE 2. Counsel for the Parties verbally met and conferred, and exchanged email, to arrive

at the proposed schedule regarding the close of discovery and a briefing schedule for the Summary Judgment Motion to be filed by Synopsys and the Customer Defendants, the Motion in Limine regarding Dirkes Thesis to be filed by Ricoh, and other pre-trial dates.
Event Summary Judgment Motion by Synopsys and Aeroflex Defendants Motion in Limine re Dirkes by Ricoh Production of updated damages information by Aeroflex Defendants Opposition to Summary Judgment Motion and Motion in Limine Reply on Summary Judgment Motion and Motion in Limine Hearing on motions Mediation Updated expert reports by party bearing burden of proof (limited to supplemental claim construction, or damages) Rebuttal expert reports Mutual exchange of Trial Exhibits in electronic form Mutual exchange of proposed jury instructions (in Word) Mutual exchange of deposition designations in electronic form Date Jan. 8, 2010 Jan. 8, 2010 Feb. 2010 Feb. 5, 2010 Feb. 19, 2010 Mar. 8, 2010 Mar. 9, 2010 June 25, 2010 July 26, 2010 Aug. 2, 2010 Aug. 2, 2010 Aug. 2, 2010

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Mutual exchange of draft pretrial statements (in Word) (including all attachments not previously served, e.g., list of claims/defense to be decided, statement of relief claimed, concise statement of all relevant facts not disputable, statement of all disputed factual issues, statement whether all or part of the action may be presented upon the agreed statement of facts, statement of stipulations requested or proposed, statement of each disputed point of law concerning liability or relief, list of witnesses to be called at trial, list of evidence to be presented from interrogatories or RFAs) Mutual exchange of counter deposition designations in electronic form Completion of expert depositions re new material in expert reports Mutual exchange of objections to jury instructions; objections to deposition designations and counter-designations in electronic form First meet and confer regarding pretrial statement; jury instructions; and deposition designations Mutual exchange of objections to Witness Lists, Exhibit Lists (in Word) Ricoh to assemble and serve revised joint pretrial statement with all attachments (in Word) Second meet and confer re Pretrial Conference Statement, and all required attachments In Limine Motions Due Joint Pretrial Conference Statement filed (including list of claims/defense to be decided, statement of relief claimed, concise statement of all relevant facts not disputable, statement of all disputed factual issues, statement whether all or part of the action may be presented upon the agreed statement of facts, statement of stipulations requested or proposed, statement of each disputed point of law concerning liability or relief, list of witnesses to be called at trial, list of evidence to be presented, through excerpts from depositions, interrogatories or requests for admission) Proposed Jury Instructions Opposition to In Limine Motions Reply in support of In Limine Motions In Limine Binders due to Court Joint Witness list, Joint Exhibit List to be lodged with Chambers Final Pretrial Conference Trial

Aug. 16, 2010

Aug. 20, 2010 Aug. 25, 2010 Aug. 27, 2009 Sept. 1, 2009 Sept. 10, 2009 Sept. 10, 2009 Sept. 15, 2010 Sept. 17, 2010 Sept. 20, 2010

Sept. 20, 2010 Sept. 27, 2010 Oct. 1, 2010 Oct. 4, 2010 Oct. 18, 2010 Oct. 18, 2010, 11am Nov. 2 - Nov 30, 2010

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Dated: December 4, 2009

Respectfully Submitted, DICKSTEIN SHAPIRO LLP BERGESON, LLP

By: /s/ Kenneth W. Brothers Gary M. Hoffman Kenneth W. Brothers Attorneys for Ricoh Company, Ltd.

Dated: December 4, 2009

WILSON SONSINI GOODRICH & ROSATI

By: /s/ Ron E. Shulman Ron E. Shulman Attorneys for Defendants and Synopsys

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SO ORDERED:

As Stipulated above.

December 14, 2009 Dated: _____________

Hon. Judge James Ware UNITED STATES DISTRICT JUDGE

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