AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 37

Consent MOTION for Extension of Time to Complete Discovery and Case Schedule by PUBLIC.RESOURCE.ORG, INC. (Attachments: #1 Text of Proposed Order Granting Defendant's Consent Motion to Extend Discovery and Case Schedule)(Bridges, Andrew)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING AND
MATERIALS dba ASTM INTERNATIONAL;
NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and AMERICAN
SOCIETY OF HEATING, REFRIGERATING,
AND AIR CONDITIONING ENGINEERS,
Plaintiffs/
Counter-Defendants,

Case No. 1:13-cv-01215-TSC

v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/
Counter-Plaintiff.
CONSENT MOTION TO EXTEND TIME FOR DISCOVERY AND CASE SCHEDULE
Defendant/Counter-Plaintiff Public Resource, Inc. (“Public Resource”) respectfully
moves to extend the fact discovery deadline and remaining deadlines on the case schedule,
currently set by Dkt. No. 30, by two months. Pursuant to LCvR 7(m), the undersigned counsel
discussed this motion with counsel for Plaintiffs/Counter-Defendants American Society for
Testing and Materials d/b/a ASTM International, National Fire Protection Association, Inc., and
American Society of Heating, Refrigerating, and Air Conditioning Engineers (“Plaintiffs”).
Plaintiffs consented to this Motion and agreed to the dates listed below.
Extending the deadlines by two months allows the parties to conduct substantial
remaining discovery in an organized and timely fashion after this Court’s resolution of the
pending protective order motion. Public Resource has discussed the schedule with Plaintiffs, and
Plaintiffs agree to the below dates as a reasonable extension of the schedule.
Public Resource (with Plaintiffs’ agreement) respectfully asks that the Court modify the

remaining schedule as follows:
Current Date

Proposed Date

Close of fact discovery

10/3/2014

12/05/2014

Joint status report

11/3/2014

1/5/2015

Opening expert disclosures

12/2/2014

2/2/2015

Opposition expert disclosures

1/16/2015

3/16/2015

Rebuttal expert disclosures

3/2/2015

5/4/2015

Reply expert disclosures

3/16/2015

5/18/2015

Close of expert discovery

4/16/2015

6/16/2015

Joint status report

4/23/2015

6/23/2015

Status conference

4/30/2015

At the Court’s convenience

Exhibit A is a Proposed Order setting these dates.

Dated: August 15, 2014

Respectfully Submitted,
/s/ Andrew P. Bridges
Andrew P. Bridges (Cal. Bar 122761)
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Counsel for
Public.Resource.Org, Inc.

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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Plaintiffs’ Consent Motion to
Extend Discovery and Case Schedule was served this 15th day of August, 2014 via CM/ECF
upon the following:
Counsel for Plaintiffs:
Jonathan H. Blavin
Jeffrey S. Bucholtz
Kenneth L. Steinthal
Joseph R. Wetzel
Anjan Choudhury
Michael Franck Clayton
J. Kevin Fee
Kelly Klaus
Michael J. Mongan

/s/ Andrew P. Bridges
Andrew P. Bridges

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