AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 46

STIPULATION re #27 Amended MOTION to Compel filed, #42 Consent MOTION for Extension of Time to Complete Discovery filed, #45 MOTION for Hearing re #27 Amended MOTION to Compel filed, #42 Consent MOTION for Extension of Time to Complete Discovery filed without opposition from Defendant -- submitted by Public.Resource.Org, Inc. and by AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC., AMERICAN PSYCHOLOGICAL ASSOCIATION, INC., NATIONAL COUNCIL ON MEASUREMENT IN EDUCATION, INC.. (Hudis, Jonathan)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC.,
and NATIONAL COUNCIL ON
MEASUREMENT IN EDUCATION, INC.,
Plaintiffs/Counterclaim Defendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.

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Civil Action No. 1:14-cv-00857-TSC-DAR
JOINT STIPULATION REGARDING
EXTENSION OF FACT AND EXPERT
DISCOVERY DEADLINES

Counsel for Plaintiffs American Educational Research Association, Inc. (“AERA”),
American Psychological Association, Inc. (“APA”), and the National Council on Measurement
in Education, Inc. (“NCME”), and Defendant Public.Resource.Org (“Public Resource”) hereby
submit the following Stipulation, and respectfully request the Court’s approval of the discovery
and pre-trial schedule provided below.
1.

Plaintiffs’ Amended Motion to Compel Discovery, Privilege Log, and Further

Initial Disclosures (Dkt. No. 27 – “Discovery Motion”) and the parties’ Consent Motion to
Extend Time for Discovery and Case Schedule (Dkt. No. 42 – “Motion re Case Schedule”) are
pending before the Court. The parties’ await rulings on these motions.
2.

As requested in the parties’ Motion re Case Schedule, and in order to allow for the

diligent and orderly completion of discovery, the parties have stipulated that the fact and expert
discovery deadlines in this case should be extended according to the schedule listed below:

Current Date (per Dkt. No. 22)

Stipulated Date

Close of Fact Discovery

March 16, 2015

May 18, 2015

Opening Expert Disclosures

April 15, 2015

June 15, 2015

Rebuttal Expert Disclosures

May 15, 2015

July 15, 2015

Replies to Rebuttal Disclosures

May 29, 2015

July 29, 2015

Final Replies to Expert Disclosures June 12, 2015

August 12, 2015

Close of Discovery

July 13, 2015

September 12, 2015

Post-Discovery Conference

July 15, 2015

September 15, 2015

3.

Pending the Court’s rulings as noted above, the parties continue in their efforts to

complete discovery, including depositions.
IT IS SO STIPULATED.
Dated: April 15, 2015

OBLON, MCCLELLAND, MAIER & NEUSTADT, LLP

By:

/s/ Jonathan Hudis
Jonathan Hudis
Attorneys for Plaintiffs
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC., and
NATIONAL COUNCIL ON MEASUREMENT
IN EDUCATION, INC.

Dated: April 15, 2015

FENWICK & WEST LLP

By:

/s/ Andrew P. Bridges
Andrew P. Bridges
Attorneys for Defendant
PUBLIC.RESOURCE.ORG

{431384US, 12076010_1.DOCX}

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC.,
and NATIONAL COUNCIL ON
MEASUREMENT IN EDUCATION, INC.,
Plaintiffs/Counterclaim Defendants,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.

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Civil Action No. 1:14-cv-00857-TSC-DAR
[PROPOSED] ORDER GRANTING
JOINT STIPULATION REGARDING
EXTENSION OF FACT AND EXPERT
DISCOVERY DEADLINES
(DKT. NO. __)

Having fully considered the Joint Stipulation to Extend Fact and Expert Discovery
Deadlines (Dkt. No. __), and for good cause shown, it is hereby
ORDERED that the Joint Stipulation to Extend Fact and Expert Discovery Deadlines
(Dkt. No. __) is GRANTED, and it is further
ORDERED that the fact and expert discovery deadlines herein are extended as follows:
Current Date (per Dkt. No. 22)

Stipulated Date

Close of Fact Discovery

March 16, 2015

May 18, 2015

Opening Expert Disclosures

April 15, 2015

June 15, 2015

Rebuttal Expert Disclosures

May 15, 2015

July 15, 2015

Replies to Rebuttal Disclosures

May 29, 2015

July 29, 2015

Final Replies to Expert Disclosures June 12, 2015

August 12, 2015

Close of Discovery

July 13, 2015

September 12, 2015

Post-Discovery Conference

July 15, 2015

September 15, 2015

Dated: _________________________

_________________________________
Hon. Deborah A. Robinson
United States Magistrate Judge

CERTIFICATE OF SERVICE
I hereby certify that on April 15, 2015, the foregoing JOINT STIPULATION
REGARDING EXTENSION OF FACT AND EXPERT DISCOVERY DEADLINES was
filed using the CM/ECF system that sent notice of the filing of these documents to all counsel of
record, and was also served via e-mail to:
Andrew P. Bridges
Matthew B. Becker
FENWICK & WEST LLP
555 California Street, 112th Floor
San Francisco, CA 94104
[e-mail]
[e-mail]
David Halperin
1530 P Street NW
Washington, DC 20005
[e-mail]
Mitchell L. Stoltz
Corynne McSherry
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
[e-mail]
[e-mail]
Counsel for Defendant
PUBLIC.RESOURCE.ORG, INC.
/s/ Jonathan Hudis
Jonathan Hudis