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)

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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: (415) 875-2300 Fax: (415) 281-1350 E-mail: Counsel for Public.Resource.Org, Inc. 2 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 3

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